Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 33

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                    There is no present obligation pursuant to a                      
               divorced decree or agreement for Ms. Krasner to pay the                
               liability of Paul’s nor is there any basis for attrib-                 
               uting this liability solely to her.  For purposes of                   
               analyzing equitable relief, normal support of a spouse                 
               does not need to be a significant benefit.                             
                  *       *       *       *       *       *       *                   
                    * * * Because of Ms. Krasner’s relatively modest                  
               level of existence, there is no reason to suggest that                 
               she “significantly benefited” from the understatement,                 
               other than receiving normal material support, much of                  
               which was provided by herself.  [Reproduced literally.]                
               On December 12, 2003, respondent’s Appeals Office (Appeals             
          Office) sent petitioner a “Notice of Determination Concerning               
          Your Request for Relief Under the Equitable Relief Provision of             
          Section 6015(f)” (notice of determination).  In the notice of               
          determination, the Appeals Office denied petitioner relief under            
          section 6015(f) with respect to taxable year 1998.  The notice of           
          determination stated in pertinent part:                                     
               We’re writing to tell you that we’ve made a decision                   
               about your January 15, 2001 request for innocent spouse                
               relief under Section 6015(f) of the Internal Revenue                   
               Code.                                                                  
                  *       *       *       *       *       *       *                   
               We’ve determined that, for the above tax year(s), we:                  
                    •    cannot allow your request.                                   
               The schedule below shows any adjustments we’ve made to                 
               your account:                                                          
                 Tax    Amount of relief Amount of relief Amount of tax               
              Period(s)  you requested    we could allow    remaining                 
             12/31/1998    $38,324.00          $0.00        $38,324.00                
          [Reproduced literally.]                                                     





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