- 13 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007