- 4 - After respondent issued the final notice dated March 27, 2002, denying equitable relief under section 6015(f) based upon the 2-year time limit, respondent nevertheless requested that his Appeals Office review petitioner’s request under the nonexhaustive list of factors of Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B. 447, 448-449. On November 19, 2003, respondent’s Appeals Office recommended not granting equitable relief under section 6015(f) after concluding the following: The fact that she indicates that she is divorced and the income was due to the non-requesting spouse does not out weigh [sic] the factors that she knew there was a balance due when she signed the return, was not forced to sign the joint return, had no filing requirement since she was a housewife and did not have to sign her name, knew what she was doing when she signed the joint return (she wanted to get a deduction for herself), the lack of economic hardship, no abuse, in good health, has assets that could be sold to pay the liability and is 45 years old with no dependents * * *. Petitioner contends that she is entitled to relief from joint and several liability under section 6015(b) and (c) and that respondent abused his discretion in denying her equitable relief under section 6015(f) for the 1993 taxable year. Accordingly, petitioner contends that she is entitled to a refund of the overpayments of her income tax liabilities that respondent used to offset the liability associated with the 1993 joint return.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011