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We’ve determined that, for the above tax years we
cannot allow your request. It has been determined that
you do not meet the statutory criteria for granting of
the innocent spouse relief. * * *
An attachment to the notice of determination stated in pertinent
part:
SUMMARY/RECOMMENDATION
Is the taxpayer entitled to innocent spouse relief
under the provisions of IRC Section 6015(f)?
No. It has been determined that the taxpayer is not
entitled to equitable relief under the provisions of
Section 6015(f). Since the representative has ex-
pressed a desire to litigate this case it is recom-
mended that a statutory notice of claim disallowance be
issued.
ADMINISTRATIVE
A related CDP case has been closed separately. The
outcome of that case has no bearing on this innocent
spouse claim.
BACKGROUND
Cynthia Beatty was born on June 6, 1955. She attended
Dulaney Valley high school, and obtained an associate
degree from Villa Julie College in 1975. Mrs. Beatty
worked as a medical secretary for Washington Hospital
Center in Washington, D.C. from 1975 to 1980. From
1981 to approximately 1990, Mrs. Beatty was a full-time
homemaker and assisted her husband with his deejay
business (carrying equipment, pulling records, attend-
ing shows, etc.) From 1990 until the summer of 1998,
Mrs. Beatty was a full-time homemaker. In the summer
of 1998, she obtained seasonal employment (May through
August) as a bartender with “BJ’s South” in Ocean City,
Maryland. The following summer (1999), Mrs. Beatty
obtained seasonal employment as a hostess for The
Twinings, a restaurant in Ocean City, Maryland. She
returned to this position during the summers of 2000
and 2001. None of Mrs. Beatty’s employment positions
involved financial responsibilities beyond basic cash-
ier duties.
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Last modified: November 10, 2007