- 21 - 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22Last modified: November 10, 2007