Vicki S. Pless and Coy E. Pless, Jr. - Page 4

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          for innocent spouse relief other than the information that is               
          reflected on the Form 8857 enclosed.”                                       
               On August 21, 2001, a tax auditor wrote to Ms. Pless                   
          concerning her claim under section 6015(f).  The letter stated,             
          among other things:  “It is important that you call me within               
          7 days of the date of this letter in order to arrange an                    
          appointment.  For your convenience, the following space is                  
          provided for you to record the appointment.”  Ms. Pless did not             
          call, but on August 29, 2001, the tax auditor called petitioners’           
          home and left a message for Ms. Pless to return the call.                   
          Ms. Pless did not return the call.  On September 7, 2001, the tax           
          auditor interviewed Ms. Pless over the telephone.  After                    
          questioning Ms. Pless about the factors considered with respect             
          to relief under section 6015(f), the tax auditor recommended                
          denial of relief because the taxpayers were still married and               
          living together; hardship was not shown; there was no indication            
          of marital abuse; there was no legal obligation (by divorce                 
          decree or agreement) for Mr. Pless to pay the liability;                    
          Ms. Pless had knowledge of the unpaid liability when she signed             
          the tax return; Ms. Pless worked periodically in Mr. Pless’s                
          office during 1998; Ms. Pless made some of the deposits into                
          personal and business bank accounts; and Ms. Pless participated             
          with Mr. Pless in paying the household expenses.                            








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