Mildred L. Jones - Page 3

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               Petitioner filed a petition for judicial review of                     
          respondent’s determination to deny her relief from joint and                
          several liability under section 6015 on her jointly filed income            
          tax returns for 1994 and 1995.  The sole issue for decision is              
          whether it was an abuse of discretion for respondent to deny                
          petitioner’s request for relief under section 6015.                         
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  When she filed her                  
          petition, petitioner was a resident of Canoga Park, California.             
               Petitioner and her now-deceased husband, Willie C. Jones,              
          filed joint Federal income tax returns for taxable years 1994,              
          1995, and 1996.  Income tax liabilities were self-assessed on the           
          joint returns, but the taxes were not paid in full.                         
               Petitioner’s husband died on August 12, 1997.  On February             
          3, 1998, following a notice and demand for payment, petitioner              
          paid respondent $8,398.56.  This amount was reflected in                    
          respondent’s records as payment in full of petitioner’s                     
          outstanding tax liabilities for 1994, 1995, and 1996.                       
               On July 11, 2003, petitioner filed a Form 8857, Request for            
          Innocent Spouse Relief, seeking relief from joint and several               
          liability on her jointly filed returns for 1994, 1995, and 1996.            
          Generally, petitioner stated that she is entitled to relief                 






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