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were made, Mr. Kunsman had not reached age 59½. The IRA
distributions were reported on Federal income tax returns that
were filed with the IRS as joint returns by petitioner and Mr.
Kunsman for 1999 and 2000. No additional tax pursuant to section
72(t) was reported. Petitioner and Mr. Kunsman separated in the
fall of 2001 and were divorced in 2002.
Petitioner first learned that there were proposed
adjustments to the 1999 tax return when respondent offset a
claimed overpayment from her 2001 tax return against a tax
balance due from 1999.1 The amount remaining unpaid for 1999 as
of March 2005 was $1,582.58.
Petitioner timely requested relief from joint and several
liability under section 6015 for 1999 and 2000. Respondent
granted petitioner relief under section 6015(c) for tax year
2000. Respondent issued a Notice of Determination denying relief
under section 6015(b), (c), and (f) for 1999. Petitioner filed a
timely petition for review of respondent’s determination.
Discussion
To support her request for relief from joint and several
liability, petitioner asserts: (1) That the 1999 tax return is
1 Apart from respondent's reference to a defaulted statutory
notice of deficiency issued to petitioner, the record does not
chronicle the deficiency procedures followed by respondent.
Petitioner does not dispute that a deficiency was properly
assessed for 1999.
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