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questionnaire was being sent to Mr. Sturges. Petitioner and Mr.
Sturges completed their respective questionnaires and returned
them to respondent.
On November 18, 2002, petitioner and Mr. Sturges filed
another offer-in-compromise offering to compromise their 2000 tax
liability for $1,000. That offer was rejected on January 15,
2003.
On February 19, 2003, respondent issued petitioner a
preliminary determination letter informing her that respondent
was denying her relief from liability because she had not
established (1) that she believed at the time she signed the
joint return that the taxes would be paid or (2) that she would
suffer economic hardship. Petitioner appealed that determination
to the IRS Appeals Office.
In April 2003, petitioner and Mr. Sturges borrowed an
additional $150,000 that was secured by a second mortgage on the
residence. They used the borrowed funds to pay the debt on their
credit cards and their daughter’s college tuition.
The Appeals Officer assigned to petitioner’s request sent
petitioner an initial contact letter on July 11, 2003. The
Appeals Officer sent a notice to Mr. Sturges on August 1, 2003.
The Appeals Officer corresponded with petitioner and her
representative over the next several months. In June 2004, the
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Last modified: May 25, 2011