Jeanine T. Foor - Page 4

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          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.                           
               This case involves unpaid taxes for the years in issue.                
          Because no understatements of tax or deficiencies are involved,             

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