- 5 - $2,050.03, of which $389 was attributable to petitioner. Petitioner and Mr. Toppi have not made any further payments on their 1998 tax liability. On October 22, 2000, petitioner and Mr. Toppi untimely filed their joint 1999 tax return reporting a tax liability in the amount of $7,437.52 and a withholding credit in the amount of $4,904.49, of which $1,884 was attributable to petitioner. Petitioner and Mr. Toppi have not made any further payments against their 1999 tax liabilities. On August 3, 2001, petitioner and Mr. Toppi signed a Form 900, Tax Collection Waiver, extending the period of limitations for collection of their 1996, 1997, 1998, and 1999 tax liabilities. On June 25, 2004, respondent received petitioner’s Form 8857, Request for Innocent Spouse Relief, and Form 12510, Questionnaire for Requesting Spouse, for tax years 1995 through 2001.1 On December 8, 2004, respondent’s Appeals officer sent petitioner a letter requesting any additional information that petitioner wanted respondent to consider in determining whether petitioner was entitled to section 6015(f) relief for the years in issue. On January 27, 2005, respondent’s Appeals Office sent petitioner a Notice of Determination denying petitioner’s request 1The record does not demonstrate that petitioner and Mr. Toppi have any tax liabilities for 2000 and 2001. We do not need to address this because, for reasons explained below, we hold that we do not have jurisdiction over the instant case.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011