Cynthia K. Beatty - Page 12




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          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. * * *                                                    






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