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the 2001 taxable year. On October 8, 2003, petitioner sent
respondent a Statement of Disagreement with respondent’s
preliminary determination as set forth in the letter dated
September 22, 2003. On December 15, 2003, respondent’s Appeals
officer sent petitioner a letter advising her that he had
received her Statement of Disagreement, which would be considered
her appeal. On January 24, 2004, the Appeals officer sent
petitioner a Notice of Determination Concerning Your Request for
Relief from Joint and Several Liability under Section 6015 and
Summary/Recommendation determining that petitioner was not
entitled to relief under section 6015 for the 2001 taxable year.
On May 14, 2004, respondent’s Appeals officer sent
petitioner a letter advising her that the earlier determination
made by its Examination Division would stand. The letter
requested a response from petitioner within 30 days. Petitioner
responded by letter dated May 23, 2004, in which she reiterated
that she should not be held responsible for the liability
stemming from the 2001 taxable year, as that liability resulted
from representations that both the IRS personnel and Mr. Khalil
Aly made to her that ITINs would be issued for Mr. Khalil Aly’s
children for the taxable years at issue.
Discussion
As a general rule, spouses making joint Federal income tax
returns are jointly and severally liable for all taxes shown on
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Last modified: May 25, 2011