- 4 -
have paid, but for the claimed losses, on items of benefit to
both of the Albins. Each loss that the Albins reported from the
shelter was later substantially reduced by respondent upon audit,
resulting in a large tax deficiency in each subject year.
On or about December 13, 2000, petitioner filed with
respondent a Form 8857, Request for Innocent Spouse Relief
(request). This request was reviewed by Robert Cipriotti
(Cipriotti), an officer in respondent’s Office of Appeals
(Appeals), after the request was denied by respondent’s
“compliance” division. Cipriotti applied the principles of Rev.
Proc. 2000-15, 2000—1 C.B. 447, to the request and recommended in
his report dated August 13, 2000, that the request be denied. On
August 21, 2002, Appeals issued to petitioner a notice of
determination stating that petitioner’s request was denied
because, respondent determined, petitioner was not eligible for
relief under any of the provisions of section 6015.
On January 10, 2003, the Albins sold for $925,000 a house
that they had purchased in 1968 for $53,500. Respondent received
$564,194.67 of the sale proceeds pursuant to a tax lien that
respondent had filed as to petitioner’s income tax liabilities
for the subject years. Afterwards, as of December 31, 2003,
3(...continued)
tax. The portions of the 1983 return which are in evidence
indicate that the Albins reported no tax liability for 1983.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011