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In response to a question in petitioner’s Form 886-A asking
whether petitioner was subject to any marital abuse during 1998,
petitioner stated: “See Report”. Petitioner did not attach any
report to petitioner’s Form 886-A.
In response to a question in petitioner’s Form 886-A asking
for any other information in support of petitioner’s position
that she is entitled to relief under section 6015 with respect to
taxable year 1998, petitioner stated: “I never saw the 1998 tax
return nor did I sign the 1998 tax return.”
In response to petitioner’s Form 886-A, respondent sent
petitioner a letter dated October 26, 2001 (respondent’s October
26, 2001 letter to petitioner). That letter stated:
We have reconsidered your claim based on the
information you submitted, however, our determination
has not changed. This is due to the fact that you had
knowledge of the balance due when you signed the re-
turn. The signature on the return is the same as your
signature on the form 8857-Innocent Spouse Relief
Request. The return was not even received until May 2,
2000. You stated you were not employed on your ques-
tionnaire but the return and your W-2 shows you had
$7,500.00 of income from Endodontics & Endodontic
Surgery PC (which is the same company Mr. Paul Krasner
worked for & had listed on his Schedule E).
You did not exercise due diligence when filing the
return. By law, taxpayers that file a joint return are
both responsible for the tax due on the original return
and any subsequent tax increases. You also did not
establish that you had a reasonable belief that the
taxes were to be paid at the time of signing the re-
turn.
Therefore your claim is being disallowed under
Internal Revenue Code 6015(f). You can still appeal
our decision to the IRS Appeals Division as stated in
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