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This case involves petitioner’s application under section
6015 for relief from joint and several liability. Specifically,
petitioner seeks a refund in accordance with respondent’s
determination that she is entitled to relief under section
6015(c) for taxable year 2001.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Dedham, Massachusetts.
There are no relevant disputed facts in this case.
On a joint Federal income tax return for the taxable year 2001,
petitioner and her husband Douglas Phillipson failed to report
$21,610 of nonemployee compensation earned by Mr. Phillipson and
$22 of dividends received by petitioner. On May 5, 2003, in
accordance with the consent to assessment by petitioner and her
husband, respondent assessed a deficiency of $6,066 plus an
accuracy-related penalty under section 6662(a) of $1,213 for the
unreported income for the year at issue.
Mr. Phillipson passed away on December 5, 2003. Prior to
his death, he and petitioner had entered into an installment
agreement with the IRS for their 2001 tax liability. On January
13, 2004, petitioner filed with the IRS a Form 8857, Request for
Innocent Spouse Relief, seeking relief from the 2001 tax
liability. Petitioner continued to pay on the installment
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