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following her divorce. When each of her sons reached the
requisite age for a driver’s license, she purchased a car for
him. The specific dates for the above occurrences cannot be
determined, and it is not clear whether the events occurred
before or after petitioner made her request for section 6015
relief.
Petitioner’s request for section 6015 relief is dated
July 12, 2000. It was received by respondent on July 17, 2000.
In her request, petitioner seeks only “equitable relief” from
income tax liabilities for the years 1995, 1996, and 1997.
Between the dates that petitioner’s request for section 6015
relief was submitted and October 2000, petitioner and her former
spouse filed a joint 1997 Federal income tax return. The portion
of the unpaid income tax reported on the joint return closely
approximates petitioner’s then-outstanding income tax liability
resulting from her 1997 separate return.3 In a final notice,
dated April 9, 2003, respondent denied petitioner’s request for
relief for all 3 years. Respondent’s determination was
reconsidered and upheld by respondent’s Appeals Office on
December 18, 2003, after the petition in this case was filed.
3 The parties have ignored the fact that at the time her
request for sec. 6015 relief was made, her 1997 income tax
liability did not result from a joint Federal income tax return,
see Raymond v. Commissioner, 119 T.C. 191, 195-197 (2002), and we
do likewise.
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Last modified: May 25, 2011