Clarissa Ybarra - Page 6

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          child tax credit.4  Reductions in the amounts of allowable                  
          credits, after taking into account the tax refund that had                  
          already been made, resulted in a 2004 tax liability of $771                 
          which, together with interest as of August 7, 2006 (the date                
          respondent issued a notice of deficiency for 2004), amounted to             
               Neither petitioner nor Mr. Olivas petitioned this Court for            
          redetermination of the deficiency for 2004.                                 
               Petitioner requested innocent spouse relief under section              
          6015 on January 9, 2006.  Respondent issued a final notice of               
          determination denying petitioner’s request on August 14, 2006.              
               Married couples may choose to file their Federal income tax            
          returns jointly.  Sec. 6013(a).  Couples filing joint returns are           
          jointly and severally liable for the taxes due thereon.  Sec.               
          6013(d)(3).  Section 6015 provides relief from liability for                
          filers of joint returns in some circumstances.  One such                    
          circumstance is set forth in section 6015(b)(1).                            
               To qualify for relief pursuant to section 6015(b)(1), the              
          requesting spouse must establish that:  (1) A joint return was              
          filed; (2) there was an understatement of tax attributable to               

               4The same results flowed from inclusion in income of the               
          retirement distribution with respect to which the amended return            
          was filed.  The $143 payment that accompanied the amended return            
          represented payment for the increase in tax due as a consequence            
          of the aforesaid retirement distribution.                                   

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