Cheryl McKnight - Page 12

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               Payments                 Petitioner & John’s Total 1995                
                              John’s   Federal Income Taxes, Penalty,                 
          Joint    Petitioner   Estate   Additions to Tax, & Interest                 
          $12,657   $8,234   $12,663              $33,554*                            

               * Respondent’s certificate of assessment reflects that                 
                    petitioner and John’s total 1995 Federal income tax               
                    liability and related amounts as determined by respondent         
                    consist of the $17,516 tax underpayment, the $6,452 tax           
                    deficiency, the $1,290 accuracy-related penalty, two              
                    separately assessed sec. 6651(a)(2) failure-to-pay additions      
                    to tax of $513 and $3,004, and interest of $4,779, all            
                    totaling $33,554.                                                 

               For years following 1995, petitioner has made a good faith             
          effort to comply with the Federal income tax laws.                          
               On February 24, 2004, petitioner requested relief under                
          section 6015(b), (c), and (f) from her joint 1995 Federal income            
          tax liability, including penalty, additions to tax, and related             
          interest paid.                                                              
               On May 26, 2004, respondent’s Compliance Office proposed to            
          grant petitioner full relief from liability for the underpayment            
          and deficiency under a combination of section 6015(f) and (b), as           
          follows, subject to any applicable refund limitations under Rev.            
          Proc. 2003-61, sec. 4.04(2), 2003-2 C.B. 296, 299:                          

          Nature of     Amount of    Compliance Office Proposed Relief                
          Liability      Liability    Amount*          Basis for                      
          Underpayment    $17,516       $17,516            Sec. 6015(f)               
          Deficiency     $ 6,452       $ 6,452             Sec. 6015(b)               
                    *  Plus additional amounts for the related penalty, additions     
                    to tax, and interest.                                             







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