Angela Barriga, f.k.a. Angela Robledo - Page 10

                                       - 10 -                                         
          the liabilities are attributable to Robledo.  Her returns for the           
          3 years subsequent to 1990 were delinquent until 1995.  We cannot           
          conclude on this record that denial of relief was an abuse of               
          discretion.                                                                 
          1991                                                                        
               The filing of a joint return is required for a taxpayer to             
          be granted relief under section 6015.  Raymond v. Commissioner,             
          119 T.C. 191 (2002).  Because she filed a separate return for               
          1991 and the subsequent attempted election of joint return status           
          was untimely under section 6013(b)(2), petitioner is not entitled           
          to relief for 1991.                                                         
          1992, 1993, and 1994                                                        
               As detailed in our Findings of Fact, respondent has made               
          concessions for 1992, 1993, and 1994.  Respondent’s Appeals                 
          Office and petitioner’s representative determined an allocation             
          of the liabilities for those years under section 6015(c).                   
          Petitioner has not contested the deficiencies or the allocations            
          and has not shown that she is eligible for additional relief                
          beyond that already granted to her.                                         
               To be eligible for relief under section 6015(b), petitioner            
          must show, among other things, that she did not know or have                
          reason to know of the understatement of tax on the subject                  
          returns; that the understatements were attributable to Robledo;             
          and that, taking into account all the facts and circumstances, it           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011