- 14 -
account be placed in an “uncollectible status” and that penalties
and interest assessed against her be abated. Id. at 141. The
taxpayer wrote another letter to the revenue agent on March 13,
1999, stating that she was current with her filing obligations
and that garnishment of her wages would cause serious financial
hardship and asking that she be relieved of the 1989 tax
liability. Id. at 141-142, 162. We treated the July 15, 1998,
and March 13, 1999, letters as a request for relief under section
6015 because of the ongoing nature of the taxpayer’s request and
the closeness in time of the July 15, 1998, letter to the July
22, 1998, enactment date of section 6015. Id. Thus, we held
that the taxpayer was entitled to a refund of those payments of
tax applied to the 1989 liability within 2 years of her refund
request. Id. at 163.
Petitioner contends that her request for relief under
section 6015 is timely under Washington. We disagree. Unlike
the taxpayer in Washington, petitioner did not make a timely
request for a refund under section 6015(f). We conclude that
Washington is distinguishable and does not control this case.
D. Whether Time Limits Provided in Section 6511 Apply in This
Case
Petitioner points out that the time for her to request a
refund under section 6511 had expired before section 6015(f) was
enacted. On the basis of this fact, petitioner contends that the
time limits provided in section 6511 should not apply in this
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011