Louise Demirjian - Page 8

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          Petitioner’s Request For Relief                                             
               On October 19, 1998, petitioner filed Form 8857, Request for           
          Innocent Spouse Relief, and requested relief from joint and                 
          several liability for the interest resulting from a “1989 Amended           
          Tax Return”.  Petitioner asserted on Form 8857 that the erroneous           
          item on that return was a “One Time Tax Exclusion on the Gain of            
          a Home Sale” in the amount of $125,000.                                     
               On February 7, 2002, respondent sent a Notice of                       
          Determination Concerning Your Request for Relief from Joint and             
          Several Liability under Section 6015 (notice of determination) to           
          petitioner denying her request for relief from joint and several            
          liability.  Respondent determined that petitioner was not                   
          eligible for relief from joint and several liability for the                
          unpaid interest because there was no joint liability as a result            
          of Apostle’s not signing the second amended joint return.                   
          Alternatively, respondent determined that, even if Apostle were             
          found to be jointly and severally liable, petitioner did not                
          qualify for relief from joint and several liability under section           
          6015(b), (c), or (f) for the unpaid interest because (1) the gain           
          realized on the sale of the New York apartment and the unpaid               
          interest resulting from that gain’s treatment on the original               
          joint return were entirely attributable to her; (2) she had                 
          knowledge or reason to know of the underpayment; (3) she would              
          not suffer economic hardship after paying the unpaid interest, as           






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