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self-employment, therefore I do not feel it is fair and just
for me to pay them. As you can see, it would cause me great
hardship to pay all of this amount owing, but that is why I
am sending in the Offer in Compromise.
I would also like to point out that I have been making
payments of $45.00 per month since I believe July of 2001
without any tardiness. If I would have known that Mr.
Tillotson was not paying the debt, I would have made sure it
was paid when it was due instead of waiting until now to
clear this up. He had a tendency to hide things from me and
spend money on other things instead of bills.
By letter dated November 10, 2003, respondent’s Appeals
officer sent to petitioner a notice of her determination that
petitioner was not entitled to relief under section 6015(f) for
the following amounts of unpaid tax liabilities, including
interest, for taxable years 1995, 1997, and 1998: $2,860,
$2,568, and $1,299, respectively. Respondent’s Appeals officer
issued to petitioner a Notice of Determination Concerning Your
Request for Relief under the Equitable Relief Provision of
Section 6015(f) on December 19, 2003, denying relief under
section 6015(f) for the taxable years 1995, 1997, and 1998.
On March 18, 2004, petitioner filed a petition with this
Court for review of respondent’s determination denying her
request for relief from joint and several liability with respect
to the 1995, 1997, and 1998 tax years.
Discussion
In general, taxpayers filing a joint Federal income tax
return are each responsible for the accuracy of their return and
are jointly and severally liable for the entire tax liability due
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