Dorothy Ann Magee - Page 25

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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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