- 11 - accountant, and respondent does not assert any tax deficiencies in the taxes reported thereon. Petitioner understood and assumed that Alimam, when he mailed the above tax returns to respondent for 1993, 1994, and 1995, was including a payment for the full tax balances shown to be due. As indicated above, however, Alimam did not include any payments in his mailing to respondent of the 1993, 1994, and 1995 joint Federal income tax returns. Twice, petitioner’s wages or bank account were levied in partial collection of the above unpaid joint Federal income taxes. Only in 1996, after separating from Alimam and after speaking to Alimam’s accountant and lawyer for the first time, did petitioner learn that Alimam had filed the above Federal income tax returns without including payments of the tax balances shown to be due thereon. On February 8, 2000, petitioner made a timely election under section 6015(f) for equitable relief from joint and several liability relating to the above 1993, 1994, and 1995 unpaid taxes attributable to Alimam’s income. On April 22, 2003, respondent issued a notice of determination denying petitioner’s request for equitable relief.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011