Dorene Bulger - Page 7

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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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