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Taxable Year Amount of Overpayment Week Applied1
1995 $193 5/12/1996
1996 585 5/25/1997
1997 246 5/10/1998
1998 226 2/21/1999
1999 237 4/16/2000
2000 349 5/13/2001
2000 2300 8/12/2001
2001 253 4/21/2002
1 Respondent testified that Monday is the typical day of the week for
applying the overpayment.
2 Amount of petitioner’s rate reduction credit for 2000.
As of December 8, 2003, the amount outstanding associated with
the 1993 joint return was $1,740.17 of accrued interest.2
In 1995 or sometime thereafter, petitioner and Mr. Hyatt
divorced.
On December 26, 2001, petitioner filed a Form 8857, Request
for Innocent Spouse Relief. Respondent issued petitioner a final
notice dated March 27, 2002, denying petitioner relief from joint
and several liability under section 6015(b), (c), and (f).
Respondent noted:
We received your request more than two years after the
date we began collection activity. IRC Sections
6015(b)(1)(E), 6015(c)(3)(B) and 6015(f) require
Innocent Spouse claims to be filed no later than two
years after the start of collection activity after July
22, 1998. The date of collection activity on your
account, after the enactment if [sic] IRC Section 6015
was 2/22/99.
2 Respondent also applied both Mr. Hyatt’s overpayment of
tax for the 2001 taxable year and Mr. Hyatt’s payments under an
installment agreement to offset the outstanding liability
associated with the 1993 joint return.
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Last modified: May 25, 2011