Louise Demirjian - Page 10

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          argues that she was unaware that there was an understatement of             
          tax on the first amended joint return that resulted in that                 
          return’s only partially correcting the understatement on the                
          original joint return.  Accordingly, petitioner contends that she           
          should be granted relief from joint and several liability for the           
          interest that accrued as a result of that understatement on the             
          first amended joint return.  In addition to her argument that she           
          is eligible for relief under either section 6015(b) or (c),                 
          petitioner argues that respondent abused his discretion by                  
          denying her equitable relief from joint and several liability for           
          the 1992-1994 interest liability under section 6015(f).                     
          Petitioner does not contend that she should be granted relief               
          from joint and several liability for the remaining amount of the            
          1990-1992 interest liability under the provisions of section                
          6015.                                                                       
               Respondent argues that petitioner is not eligible for relief           
          under either section 6015(b) or (c).  Moreover, respondent                  
          contends that there was no abuse of discretion in denying                   
          petitioner’s request for equitable relief from joint and several            
          liability for any portion of the unpaid interest under section              
          6015(f).  Respondent has not pursued the argument that petitioner           
          was ineligible for relief under section 6015 because Apostle did            
          not sign the second amended joint return.                                   
          Relief Under Section 6015(b) and (c)                                        






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