Arlene C. Ogonoski - Page 8

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          Rule 325, as amplified by King v. Commissioner, 115 T.C. 118                
          (2000), that respondent had notified Mr. Ogonoski that petitioner           
          had filed a claim for relief from joint and several liability in            
          this case.  Mr. Ogonoski has not intervened in this case.                   
          Discussion                                                                  
               Issue 1.  Relief Under Section 6015                                    
               Generally, married taxpayers may elect to file a joint                 
          Federal income tax return.  Sec. 6013(a).  After making the                 
          election, each spouse generally is fully responsible for the                
          accuracy of the return and jointly and severally liable for the             
          entire tax due for that year.  Sec. 6013(d)(3); Butler v.                   
          Commissioner, 114 T.C. 276, 282 (2000).                                     
               Petitioner requested relief under section 6015 from                    
          liability for the taxes reported on her 1989 through 1997 joint             
          returns that were not paid when the returns were filed.                     
          Respondent determined petitioner was not entitled to the                    
          requested relief.  In requesting relief, petitioner argues that             
          when she signed the returns, it was reasonable for her to believe           
          Mr. Ogonoski would pay the reported tax liabilities at some                 
          future time because there was a similar pattern of nonpayment for           
          prior years, followed by his payment of the balances due for                
          those years.  Petitioner also argues she will suffer economic               
          hardship if relief is not granted.                                          
               If a taxpayer’s request for relief under section 6015 is               
          denied, the taxpayer may petition this Court under section                  




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