- 33 - 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.]Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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