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6015 (relief from joint liability) with respect to her 1997
Federal income tax. More specifically, the issue is whether
petitioner’s claim for section 6015 relief is barred based on
respondent’s determination that petitioner’s claim for relief was
filed more than 2 years after the first collection activity was
undertaken toward collection of petitioner’s 1997 unpaid tax.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made a part hereof.
Petitioner’s legal residence at the time the petition was filed
was Modesto, California.
For the year 1997, petitioner filed a joint Federal income
tax return with her spouse, George A. Ferris. She and Mr. Ferris
were divorced in March 2003. On the 1997 income tax return,
petitioner and Mr. Ferris reported gross income of $46,223,
consisting of wage and salary income of $7,770 and other income
from two trade or business activities she and Mr. Ferris
independently conducted. The return showed a tax of $9,074 and
Federal income tax withholdings of $43. The return also included
a computation of $333 as an estimated tax penalty. Except for
the $43 in tax withholding, no other payments were made with the
return. No adjustments were made to the return, the tax was
assessed, and no notice of deficiency was issued with respect to
the return.
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Last modified: May 25, 2011