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VI. Conclusion
The Court found the testimony of petitioner to be sincere.
It appears from the record that when petitioner and Mr. Magee
divorced, he left petitioner and their child with scant financial
resources and significant debt. However, since petitioner
intended to file a joint return with Mr. Magee, she should have
been aware that each joint filer would be jointly and severally
liable for any tax shown due on the return. The Court is
sympathetic to petitioner’s case; nevertheless, on this record,
the Court concludes that respondent’s denial of equitable relief
was appropriate. Therefore, petitioner is not entitled to relief
under section 6015(f) and is liable for the amount shown due on
the tax return. Accordingly, collection action by levy of
petitioner’s unpaid 1996 tax liability as reflected in the notice
of determination may proceed.
The Court has considered all of petitioner’s contentions,
arguments, requests, and statements. To the extent not discussed
herein, we conclude that they are meritless, moot, or irrelevant.
To reflect the foregoing,
Decision will be entered
for respondent.
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