Donna M. Keitz - Page 6

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                           House payment         $693                                 
                           Oil               200                                      
                           Gas & electric         200                                 
                           Auto fuel               50                                 
                           Car insurance           51                                 
                           Phone                   35                                 
                           Clothing               200                                 
                           Recreation             160                                 
                           Credit card            80                                  
                           Food                   800                                 
                           Medical                60                                  
                           Hair cuts              50                                  
                           Cable                  42                                  
                           Lawyers                100                                 
                           Child care             100                                 
                                                                                     
               On June 25, 2001, respondent determined petitioner was not             
          entitled to relief from the deficiency for tax year 1997 pursuant           
          to section 6015 because petitioner did not file a joint tax                 
          return for that year.  Respondent granted petitioner relief from            
          joint liability for the deficiencies for 1995 and 1996 pursuant             
          to section 6015(c).                                                         
               Despite the parties' agreement that the 1996 underpayment is           
          solely attributable to Mr. Keitz and respondent's examiner's                
          determination that Mr. Keitz bears the legal obligation for the             
          underpayment, respondent determined petitioner was not entitled             
          to relief for the $4,850 underpayment of tax for tax year 1996              
          pursuant to section 6015(f).  Respondent contended that                     
          petitioner:  (1) Failed to prove a belief that the tax would be             
          paid; (2) did not fulfill her duty to inquire as to whether the             
          tax would be paid; and (3) failed to show that it would be an               
          economic hardship for her if relief were denied.                            





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Last modified: May 25, 2011