- 18 - Petitioner’s Claim for Section 6015 Relief On or about August 29, 2000, petitioner filed Form 8857, Request for Innocent Spouse Relief (And Separation of Liability and Equitable Relief), on which she requested relief pursuant to section 6015(b) and (f) for 1980 through 1997.8 On August 24, 2001, respondent sent petitioner a preliminary determination denying petitioner’s request for relief under section 6015(b), (c), and (f) for 1980 through 1986. Respondent denied relief on the basis that: (1) Petitioner had actual knowledge or reason to know of the item giving rise to the understatement; (2) petitioner did not show that the erroneous items were attributable to her spouse; (3) petitioner did not demonstrate that it would be inequitable to hold her liable for the deficiency attributable to the understatement; and (4) petitioner did not meet the marital status requirements of section 6015(c). On September 17, 2001, petitioner timely submitted a written appeal of respondent’s determination to the IRS Appeals Division. On December 4, 2002, respondent issued a notice of determination in which he concluded that petitioner did not qualify for relief from joint and several liability under section 6015(b), (c), or (f). With respect to his determination under 8On Nov. 14, 2000, respondent sent petitioner a letter that indicated petitioner’s request for relief with respect to the 1987 through 1997 taxable years was premature.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011