Joan Phyllis Levy - Page 43

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          returns for those years.  See Knorr v. Commissioner, T.C. Memo.             
          2004-212 (noting Tax Court’s consistent application of principle            
          that provisions providing relief from joint and several liability           
          were designed to protect the innocent, not the intentionally                
          ignorant); cf. Ewing v. Commissioner, 122 T.C. at 47-49.                    
               Levy’s concealment of his nonpayment of taxes and gambling             
          problem weighs in favor of granting petitioner relief for 1991              
          through 1995, but not for 1996 through 1999.                                
               9.  Conclusions                                                        
               Although it is undisputed that petitioner meets the                    
          threshold conditions of section 4.01 of Rev. Proc. 2000-15,                 
          supra, she does not qualify for relief under section 6015(f) for            
          1991 through 1999 under section 4.02 of Rev. Proc. 2000-15                  
          because, among other things, she has failed to establish that she           
          will suffer economic hardship if relief is not granted.                     
          Petitioner, however, may still qualify for relief under section             
          6015(f) if, taking into account all the facts and circumstances,            
          it is inequitable to hold petitioner liable for all or part of              
          the unpaid liability.  Rev. Proc. 2000-15, sec. 4.03, 2000-1 C.B.           
          at 448-449.                                                                 
               As previously discussed, petitioner had no knowledge or                
          reason to know, at the time she signed the returns for 1991                 
          through 1995, that Levy would not pay those tax liabilities.                
          Indeed, Levy concealed from her for some time his nonpayment of             






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