Shirley H. Startzman, Petitioner, and Larry G. Easler, Intervenor - Page 6

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          relief was being disallowed because petitioner filed her claim              
          more than 2 years after the first collection activity.                      
          Similarly, respondent’s Appeals Office determined that                      
          petitioner’s claim was untimely and, in a letter dated November             
          4, 2004, disallowed petitioner’s request for section 6015 relief            
          regarding taxable year 1997.                                                
               On January 31, 2005, petitioner timely filed a petition with           
          this Court seeking a review of respondent’s determination denying           
          her request for section 6015 relief.  Respondent’s counsel                  
          determined that petitioner’s request for section 6015 relief was            
          timely and asked the innocent spouse unit to determine whether              
          petitioner was entitled to relief.  On August 12, 2005,                     
          respondent’s innocent spouse unit determined that petitioner was            
          not entitled to relief under section 6015(b), (c), or (f) because           
          petitioner had actual knowledge of the omitted income giving rise           
          to the deficiency and, by not reviewing the return, she did not             
          satisfy her duty to inquire.                                                
                                     Discussion                                       
               In general, spouses filing a joint return are jointly and              
          severally liable for the accuracy of the return and for the full            
          tax liability.  Sec. 6013(d)(3).  Section 6015(b), (c), and (f)             
          provide exceptions to the general rule in certain circumstances.            
          Section 6015 applies to liabilities arising after July 22, 1998,            
          and to liabilities arising on or before July 22, 1998, that                 






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