- 25 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Last modified: May 25, 2011