- 12 -
at that time, and (3) all bank statements and canceled checks
that petitioner had with respect to any bank accounts that
petitioner maintained individually, that Mr. Beatty maintained
individually, or that they maintained jointly. On November 5,
2002, petitioner provided such documents to respondent’s repre-
sentative.
On November 4, 2003, petitioner and Mr. Beatty filed Form
656, Offer in Compromise. In response, an Internal Revenue
Service (IRS) offer manager returned that form by letter dated
November 21, 2003. That letter stated in pertinent part:
We are returning your Form 656, Offer in Compro-
mise for the following reason(s):
An offer will not be considered while a bankruptcy
proceeding is open.
All required tax returns have not been filed.
On August 19, 2004, respondent’s Appeals Office (Appeals
Office) sent petitioner a “Notice of Determination Concerning
Your Request for Relief under the Equitable Relief Provision of
Section 6015(f)” (notice of determination). In the notice of
determination, the Appeals Office denied petitioner relief under
section 6015(f) with respect to, inter alia, taxable years 1988
through 1997 and 2000. The notice of determination stated in
pertinent part:
We’re writing to tell you that we’ve made a decision
about your February 28, 2002 request for innocent
spouse relief under Section 6015(f) of the Internal
Revenue Code. * * *
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: November 10, 2007