Deborah Ann Puckett - Page 6

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          On July 9, 2003, petitioner appealed to respondent’s Appeals                
          Office on the grounds that she filed jointly to lower Mr.                   
          Puckett’s tax liability and with the understanding that Mr.                 
          Puckett would pay the tax owing.                                            
               On November 3, 2004, respondent issued a Notice Of                     
          Determination Concerning Your Request For Relief Under The                  
          Equitable Relief Provision Of Section 6015(f).  In the notice,              
          respondent determined (1) that petitioner failed to meet her                
          burden of establishing that she had a reasonable belief that the            
          taxes would be paid timely and (2) that petitioner failed to                
          establish that she would suffer an economic hardship if she were            
          required to pay some or all of the tax.                                     
               Petitioner filed an imperfect petition, followed by an                 
          amended petition, contesting respondent’s determination.3  The              
          amended petition stated:                                                    
               The debt was due to my ex-husband not paying his social                
               security taxes.  I had been instructed by my accountant                
               to sign a joint tax return even though I was separated                 
               from my ex-husband in an attempt to “help with divorce                 
               relations” by lowering the amount he owed.  And also                   
               told I would not be held responsible.  I was then told                 
               by them to file an innocent spouse form which a former                 
               IRS caseworker told me 2 months ago “never works”.                     




               3  Mr. Puckett did not file a Notice of Intervention under             
          Rule 325(b).  He did, however, file a statement with respondent’s           
          Appeals Office stating that he was assured by both his accountant           
          and his wife that there would not be any taxes due for 2000                 
          because of the losses related to his wife’s business.                       





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