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review respondent’s determination for the 1989 through 1997 tax
years. Petitioner also requested this Court to review whether
the period of limitation for collection of her unpaid tax
liability for 1989 has expired.
We sustain respondent’s determination that petitioner is not
entitled to relief under section 6015(f). We lack jurisdiction
to review the limitation issue.
Background
Some of the facts have been stipulated and are so found.
Petitioner lived in Burlington, Connecticut, when she filed her
petition in this case. From 1989 to the present, petitioner has
been married to Arthur Ogonoski (Mr. Ogonoski) and lived with him
in the same household. Since 1994, petitioner and Mr. Ogonoski
have lived in a house they own, at 348 George Washington Turnpike
in Burlington, that they purchased for $71,000. The house is
subject to a mortgage loan (from an individual rather than a
lending institution) that appears to bear an above-market rate of
interest.
From 1989 to April 1994 petitioner was employed part time as
an office temp; since April 1994 petitioner has been employed as
a secretary/clerk. At all times relevant, Mr. Ogonoski has
worked as a self-employed excavator.
Petitioner and Mr. Ogonoski have five children; they
reported all five children as dependents on their 1989 through
1994 tax returns, four children as dependents on their 1995
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