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documentation. However, the documentation is extensive and we do
not want to overwhelm you.”
On June 17, 2002, Mr. Bulger died. Neither petitioner nor
petitioner’s counsel informed Appeals Officer Hackmeister of Mr.
Bulger’s death.
On December 5, 2002, respondent issued a Notice of
Determination Concerning Your Request for Relief From Joint and
Several Liability Under Section 6015 (notice of determination)
denying petitioner’s request for relief. Respondent denied
relief because: (1) Contrary to section 6015(b) requirements,
the erroneous item was attributable to both petitioner and Mr.
Bulger, and petitioner had knowledge of the item that caused the
understatement; (2) petitioner did not meet the marital status
requirements of section 6015(c); and (3) it would not be
inequitable to hold petitioner responsible for the understatement
under section 6015(f). Appeals Officer Hackmeister’s narrative
explaining the reasons for denying petitioner relief also stated
as follows with respect to section 6015(c):
Requirements:
2. There is a deficiency of tax allocable to the non-
requesting spouse.
NOT MET
3. The spouse seeking relief did not have actual
knowledge of the deficiency at the time the return
was signed.
NOT MET
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