- 4 - based on the conclusions of two revenue agents, Ann Hoel and Al Petroff (Mr. Petroff). In analyzing petitioner’s entitlement to equitable relief under section 6015(f), the revenue agents determined: (1) Petitioner was divorced at the time she requested relief; (2) petitioner would suffer economic hardship if relief was not granted; (3) petitioner did not significantly benefit from the unpaid tax liabilities; (4) petitioner had made a good faith effort to comply with the Federal income tax laws in the tax years following the years at issue; and (5) there were no perceptible asset transfers between petitioner and Mr. Foor. The agents determined that petitioner knew or had reason to know that the tax liabilities would not be paid and that the liabilities were not solely attributable to Mr. Foor. The revenue agents noted that petitioner was responsible for at least a portion of the underpayments because of inadequate withholding. Petitioner filed a petition under section 6015(e)(1) seeking review of respondent’s determinations for the taxable years 1983, 1984, 1985, 1987, 1990, and 1991. The petition lists section 6015(b), (c), and (f) and alleges that it would be inequitable to hold petitioner responsible for the unpaid taxes. OPINION This case involves unpaid taxes for the years in issue. Because no understatements of tax or deficiencies are involved,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011