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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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