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During their divorce proceedings, petitioner and Mazzilli
agreed that Mazzilli should be responsible for the payment of the
Federal income tax liabilities for 1992 through 1995. As of the
time of trial on May 3, 2004, Mazzilli had not paid these
liabilities.
Petitioner’s Request for Relief From Joint and Several Liability
On February 2, 2001, petitioner requested relief from joint
and several liability under section 6015(f) for 1992 through
1995. On November 21, 2002, the Internal Revenue Service sent to
petitioner a Notice of Determination Concerning Your Request for
Relief under the Equitable Relief Provision of Section 6015(f)
(notice of determination) with respect to those years. Attached
to the notice of determination was a Form 886-A, Explanation of
Adjustments, that set forth the following reasons for the denial
of petitioner’s request for relief:
1. Attributatable [sic] to the Non-Requesting
Spouse--Portions of the unpaid liability are
attributable to under withholding on your wages.
2. No Knowledge of [sic] Reason to Know--You had
reason to know that the liabilities would not be
paid when you signed the returns because
outstanding tax liabilities existed from prior
year returns that had not been paid, mortgage
payments were in * * * arrears and your ex-spouse
was contemplating filing for bankruptcy.
3. Noncompliance with Federal Income Tax Laws--You
have not filed tax returns for tax years 1997 and
1999 and have an outstanding tax liability for tax
year 2000.
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Last modified: May 25, 2011