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On May 23, 2003, CCISO issued petitioner a preliminary
determination denying her section 6015 relief for all years. The
letter explained that CCISO had denied petitioner relief under
section 6015(b) and (c) for the 1993 and 1995 understatements of
tax because she had constructive and actual knowledge of the
computational errors, the errors were on the returns, and
petitioner, having a duty to review the returns, failed to do so.
The letter explained that CCISO denied petitioner relief under
section 6015(f) for the understatements and/or underpayments of
tax for all years because petitioner did not establish that she
believed the tax would be paid at the time the returns were filed
and, having a duty to inquire as to how the taxes would be paid,
failed to do so. Additionally, there were balances owed for
previous years when the returns were filed and a bankruptcy had
been filed. The letter informed petitioner that she could
request that an Appeals Office review the preliminary
determination.
Petitioner, Mr. Smith, and Mr. Scott and his new wife met
with petitioner’s clergyman, a bishop of the Church of Jesus
Christ of Latter-Day Saints (the LDS Church). Mr. Scott told the
bishop that he had filed erroneous Federal income tax returns and
had kept that fact from petitioner and that he put the returns in
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Last modified: November 10, 2007