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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.
OPINION
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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