Marion Goldin - Page 7

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          section 6015(c) for all amounts owed as of July 22, 1998, but               
          that her request for refund was untimely.                                   
               By letter to respondent’s Appeals officer dated December 19,           
          1999, petitioner told respondent that she disagreed with                    
          respondent’s conclusion because it meant she was not entitled to            
          a refund.  On January 23, 2001, petitioner faxed copies of her              
          July 31, 1995, letter and Kohl’s October 3, 1995, letter to                 
          respondent’s Appeals officer.  By letter to respondent’s Appeals            
          officer dated March 1, 2001, petitioner said that she did not               
          understand why she was not entitled to a refund.  By letter to              
          respondent’s Appeals officer dated March 16, 2001, petitioner               
          withdrew her claims under section 6015 for 1981 and 1982.                   
               Respondent determined on July 20, 2001, that petitioner                
          (1) is entitled to relief under section 6015(c) in the amount of            
          tax owed as of July 22, 1998 ($5,219 for 1983 and $48 for 1984),            
          (2) is not entitled to equitable relief under section 6015(f) for           
          1983 and 1984, and (3) is not entitled to a refund for 1983 and             
          1984 because her request for a refund was not timely.  Petitioner           
          timely filed a petition and an amended petition in which she                
          seeks review of respondent’s determination.                                 
                                       OPINION                                        
          A.   Petitioner’s Contentions                                               
               Petitioner contends that it is inequitable to hold her                 
          jointly liable for tax she paid before July 23, 1998, that is               






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