Magdalena Pacheco - Page 22




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         Employer’s Annual Federal Unemployment (FUTA) Tax Return for 1995            
         and 1996, and (3) State of California Employment Development                 
         Department, Form DE7, Annual Reconciliation Return, for 1995 and             
         1996.  Petitioner admitted that she had signed the foregoing                 
         documents and had represented herself as the owner of Contractor.            
         Because she was the owner of Contractor, the entire 1997                     
         deficiency is allocable to her.  See sec. 1.6015-3(d), Income Tax            
         Regs.                                                                        
              The Court has reviewed all the evidence presented and finds             
         that petitioner had actual knowledge of the items giving rise to             
         the deficiency for 1997.  The Court holds that respondent did not            
         err in denying petitioner relief from joint and several liability            
         under section 6015(c) for 1997 in his notice of determination                
         dated January 12, 2005.                                                      
              To reflect the foregoing,                                               
                                                 Decision will be entered             
                                            for respondent.                           


















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