Angela Barriga, f.k.a. Angela Robledo - Page 11

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          would be inequitable to hold her liable for the deficiency in tax           
          attributable to the understatement.  In view of petitioner’s                
          education, we do not accept her generalized allegations that she            
          knew nothing about tax matters for the years in issue.  She did             
          not file timely returns for 1992, 1993, or 1994, even though she            
          received compensation as a school teacher during those years.               
          She acknowledges that, at the time the returns were filed, she              
          was represented by an attorney and a certified public accountant.           
          Petitioner and Robledo lived in a community property State and              
          together owned rental real estate, some of which petitioner was             
          awarded in the divorce decree.  Petitioner seeks to be relieved             
          of liability for taxes on her own income as well as that of                 
          Robledo, asserting that she was unfairly treated in the divorce             
          proceedings and in the bankruptcy court.  She has not satisfied             
          the requirements for relief under section 6015(b).  (The relief             
          that she was granted under section 6015(c) includes any relief              
          that she might have claimed under section 6015(b) with respect to           
          items attributable solely to Robledo.)                                      
               For the same reasons, and applying the factors discussed               
          with respect to 1990, we cannot conclude that denial of relief to           
          petitioner under section 6015(f) was an abuse of discretion.                
          We have considered the other arguments made by petitioner.  They            









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