- 3 -
claim by petitioner under section 6015, respondent’s
determinations contained in the notice of deficiency are not in
dispute.
Petitioner knew of Ms. Becherer’s employment with the three
employers. Petitioner occasionally assisted Ms. Becherer in
performing her employment duties for Trader Publications and
Pennysaver.
When the 1996 Federal income tax return was prepared,
petitioner was a sophomore or junior in college, and Ms. Becherer
held a high school general equivalency diploma. Petitioner had
an opportunity to review the 1996 Federal income tax return
before the return was filed. Petitioner currently holds a degree
in communications from the University of Miami and is employed as
a video editor for E-Entertainment Network.
Discussion
In general, spouses filing joint Federal income tax returns
are jointly and severally liable for all taxes due. Sec.
6013(d)(3). Under certain circumstances, however, section 6015
provides relief from this general rule. Except as otherwise
provided in section 6015, petitioner bears the burden of proof.3
3 Petitioner does not contend that sec. 7491(a) is
applicable to this case, nor is there evidence that the
examination commenced after July 22, 1998. Also, we note that
some documents in the record indicate that the examination began
prior to July 22, 1998.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011