Yvonne E. Thurner - Page 7

                                        - 7 -                                         
               D.  Forms 8857                                                         
               On December 21, 2000, petitioner Yvonne E. Thurner filed               
          with respondent Form 8857, Request for Innocent Spouse Relief,              
          requesting relief from joint and several liability under section            
          6015 with regard to the taxable years 1980, 1981, 1990, and 1992.           
          On August 2, 2001, petitioner Scott P. Thurner filed with                   
          respondent Form 8857 requesting relief from joint and several               
          liability under section 6015 with regard to the taxable years               
          1980, 1981, 1990, and 1992.  Respondent did not respond to                  
          petitioners’ claims for relief from joint and several liability.            
               E.  Petitions                                                          
               On August 10, 2001, petitioner Yvonne E. Thurner filed with            
          the Court a petition for determination of relief from joint and             
          several liability on a joint return with regard to her tax                  
          liabilities for 1980, 1981, 1990, and 1992.  On February 15,                
          2002, petitioner Scott P. Thurner filed with the Court a petition           
          for determination of relief from joint and several liability on a           
          joint return with regard to his tax liabilities for 1980, 1981,             
          1990, and 1992.  Although the petitions are not entirely clear,             
          it appears that petitioners claim that they are entitled to                 
          relief under section 6015(b) and (f).2                                      

               2  The record indicates that, at the time the petitions were           
          filed in these cases, petitioners were not divorced or legally              
          separated and that petitioners continued to live together.                  
          Therefore, petitioners would not qualify for relief from joint              
          and several liability under sec. 6015(c).                                   





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011