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under section 6651(a)(1)1, in the amount of $2,625 for taxable
year 1990, and in the amount of $5,280 for taxable year 1991, for
failing to timely file tax returns for those taxable years.
Respondent also determined that petitioner is liable for the
accuracy-related penalty pursuant to section 6662(a), in the
amount of $4,192 for taxable year 1990, and in the amount of
$5,418 for taxable year 1991. The sole issue for decision is
whether petitioner qualifies for "innocent spouse" relief under
section 6013(e) for either taxable year 1990 or 1991. We hold
that she does not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein. At the time the petition was filed in this
case, petitioner resided in Menomonie, Wisconsin.
Petitioner and her former husband, Carl L. Peterson (Mr.
Peterson), were married in 1973. They were divorced in 1993.
The couple filed a joint Federal income tax return for taxable
year 1990 on October 9, 1991. They filed their joint Federal
income tax return for taxable year 1991 on August 18, 1992.
Petitioner received a bachelor's degree in home economics
from the University of Wisconsin in 1958. She received a
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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