Ruth E. Neal - Page 11

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          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.                                                             








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