Roxanne M. Toppi - Page 5

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          $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.                     





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