- 4 -
In 1995, petitioner and Robledo each filed returns for 1991
using the filing status of “married filing separate return”.
Petitioner’s return for 1991 was filed in March 1995 and reported
tax due of $38,406 and an underpayment of $32,625. On
November 9, 1995, respondent sent a notice of deficiency for 1991
to petitioner. In or after October 1995, petitioner and Robledo
attempted to file an amended return for 1991 using the status of
“married filing joint return”.
In September 1995, Robledo filed separate returns for 1992
and 1993. On October 12, 1995, joint Forms 1040X, Amended U.S.
Individual Income Tax Return, for 1992 and 1993 were filed. The
amended returns claimed overpayments for 1992 and 1993 in the
amounts of $17,106 and $20,386, respectively. Also on
October 12, 1995, petitioner and Robledo filed a joint Form 1040
for 1994 claiming an overpayment of $4,675. Each of the joint
returns reported wages paid to petitioner, Schedule C, Profit or
Loss From Business, income of Robledo, and rental income from
various properties owned by petitioner and Robledo.
In or about 1999, petitioner, represented by a certified
public accountant, filed a request for section 6015 relief.
During the Appeals process, petitioner was allowed partial relief
from joint and several liability under section 6015(c) for 1992,
1993, and 1994. Respondent and petitioner’s representative
together determined the appropriate allocation of the deficiency
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011