Judith A. Madden - Page 9

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         Appeals Officer issued petitioner a final notice of determination            
         denying her relief from liability.                                           
              Petitioner and Mr. Sturges own land in Colorado, and they               
         are income beneficiaries of a charitable remainder trust.                    
         Petitioner and Mr. Sturges created and funded the charitable                 
         remainder trust in December 1999.  Petitioner and Mr. Sturges are            
         entitled to 5 percent of the value of the trust property                     
         annually.  The remainder goes to the “education system” of the               
         Commonwealth of Massachusetts.  The record does not contain any              
         information as to the amount contributed to the charitable                   
         remainder trust in 1999.                                                     
              Petitioner owns a three-bedroom, single-bath house in mid-              
         State New York that she inherited from her parents.  Petitioner              
         rents the property for an amount equal to the expenses related to            
         maintaining the property.  There is no mortgage on the property.             
              Mr. Sturges has earned approximately $115,000 each year for             
         the past several years.                                                      
              Petitioner and Mr. Sturges have filed Federal income tax                
         returns and paid all taxes owed for all years since 2000.                    
              Petitioner requested relief under section 6015(f) from                  
         liability for the payment of the tax reported on the 2000 joint              
         return but not paid when the return was filed.  Respondent                   

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