- 2 - 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 1995Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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