Natalie W. McGee - Page 4

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          offset).  At or about that time, respondent sent petitioner a               
          letter notifying her of the offset.  This letter was not in                 
          respondent’s administrative file and is not a part of the record,           
          but based on petitioner’s testimony and the parties’ agreement at           
          trial, this notice is consistent with a similar notice petitioner           
          received on August 13, 2001.  Neither of the notices sent to                
          petitioner regarding the offset advised petitioner of her                   
          potential rights to relief under section 6015.  As a result,                
          petitioner was unaware of those rights until she hired an                   
          attorney in late 2001 after a problem arose with her credit                 
          rating because a notice of Federal tax lien had been filed on her           
          residence.  On February 17, 2002, petitioner filed with                     
          respondent an executed Form 8857 with respect to the 1997                   
          liability.                                                                  
          Discussion                                                                  
               Section 6013(d)(3) provides that married individuals who               
          file a joint return are jointly and severally liable for the tax            
          arising from the return.  Section 6015 provides that                        
          notwithstanding section 6013(d)(3), an individual who filed a               
          joint return may seek relief from joint liability under three               
          specific alternatives set forth in subsections (b), (c), and (f)            
          of section 6015.  This case only involves a request for relief              
          under subsection (f), which provides that the Secretary may                 
          relieve an individual of joint liability if subsections (b) and             






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