- 30 -
relief from the liabilities is not granted given her current
level of income. See Alt v. Commissioner, supra at 314-315; Von
Kalinowski v. Commissioner, T.C. Memo. 2001-21; Walters v.
Commissioner, T.C. Memo. 1998-111; Dillon v. Commissioner, T.C.
Memo. 1998-5.
Christopher testified that he and petitioner owe $96,000 to
the IRS for their 1981 through 1986 tax years.7 In her “Appeals
Transmittal and Case Memo”, Ms. Flandez listed the tax owed for
1982 through 1986 as $20,300. According to an IRS transcript, as
of August 26, 1998, petitioner and Christopher owed $20,300 in
tax and approximately $61,000 in interest for their 1982 through
1986 tax years.
The Form 433-A, Collection Information Statement for Wage
Earners and Self-Employed Individuals, that petitioner and
Christopher signed on February 28, 2003, contained the following
statements: Petitioner and Christopher owned their home; they
had no dependents they could claim on their tax return; they had
a Bank of America checking account with a balance of $4,000;
7 We note that the 1981 tax year is not in issue. See
supra note 2.
Additionally, on brief petitioner makes claims regarding the
total liability relating to the Hoyt investment for 1981 through
1996. Petitioner’s tax years 1987 through 1996 also are not
before the Court. Even if they were, according to petitioner’s
own estimate of the total tax liability, petitioner and her
husband have substantial assets (real property and investments)
and credit that could be used to pay the total tax liability for
1981 through 1996 without creating economic hardship.
Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: May 25, 2011