- 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.]
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