Angela Barriga, f.k.a. Angela Robledo - Page 6

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          6015.  Sec. 6015(a).  A requesting spouse may request relief from           
          liability under section 6015(b) or, if eligible, may allocate               
          liability according to provisions under section 6015(c).  Sec.              
          6015(a).  If relief is not available under section 6015(b) or               
          (c), an individual may seek equitable relief from joint and                 
          several liability if “taking into account all the facts and                 
          circumstances, it is inequitable to hold the individual liable              
          for any unpaid tax”.  Sec. 6015(f).                                         
               Petitioner has failed to address the applicable statutory              
          provisions, the adjustments involved in respondent’s                        
          determination, or the relevant facts.  Petitioner argues that she           
          did “not know the facts as to amounts owed, when, or why, as                
          petitioner never had anything to do with these matters”.                    
          Petitioner generally claims that the division of property                   
          pursuant to the divorce decree was not equitable; she received              
          properties that were foreclosed; the divorce decree was signed              
          without notice to her; and “the system” failed to treat her                 
          fairly.                                                                     
          1989 and 1990                                                               
               Under section 6015(b) and (c), relief from joint and several           
          liability is available only from proposed or assessed                       
          deficiencies.  Sec. 6015(b)(1)(D), (c)(1).  Neither section                 
          6015(b) nor section 6015(c) permits relief from liabilities that            
          were reported on a return but remained unpaid.  Hopkins v.                  






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