- 9 - 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. RespondentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011