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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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Last modified: November 10, 2007