- 14 - • You signed other correspondence/documents relating to the Hoyt partnerships. • The size of the loss/deduction in relation to the income reported on the return would reasonably put you on notice that further inquiry would need to be made. • You have not shown that you satisfied your duty of inquiry at the time the return was prepared and signed to make sure the return was correct. • Your investment in the Hoyt partnerships was a joint investment with your spouse giving you actual knowledge of the item giving rise to the deficiency. You cannot claim relief under section 6015(b) with respect to your own erroneous items and you have not shown that the erroneous items are attributable to your spouse. You have not shown that it would be inequitable, taking into account all of the facts and circumstances, to hold you liable for the deficiency attributable to the understatement. Respondent also explained why petitioner did not qualify for relief under section 6015(c). Regarding section 6015(f), respondent wrote: “You have not shown that it would be inequitable, taking into account all of the facts and circumstances, to hold you liable for the deficiency attributable to the understatement.” On or about April 9, 2002, Ms. Sneed forwarded petitioner’s case to respondent’s Appeals Office. Appeals Officer Gloria Flandez was assigned to review petitioner’s case. In NovemberPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011