Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 27

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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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