Arlene C. Ogonoski - Page 2

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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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