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section 6621(c) (formerly section 6621(d)), but she was not
liable for additions to tax under section 6653(a)(1) or (2).
In early 1998, respondent’s Appeals Office began
consideration of Judith’s claim for innocent spouse relief. A
letter to Judith dated July 8, 1998, communicated, in part, the
following:
This letter is to inform you that all the facts
and circumstances that serve as the basis for your
claim for IRC 6013(e) “Innocent Spouse” relief were
carefully considered. In addition, this office served
notice of the claim on Thomas Corson, and requested
that he furnish any information relevant to a
determination as to whether or not such relief would be
appropriate. In response, Mr. Corson has furnished
information that must be given due consideration in
this matter.
The Appeals officer then concluded: “It would be my
recommendation that the requirements of the law are not met and
that Innocent Spouse relief could not be approved.”
On July 22, 1998, the Restructuring Act was enacted. The
statute, among other things, revised and expanded the relief
available to spouses filing joint returns, and Judith’s attorney
informed the Appeals officer that Judith elected to have the
newly promulgated section 6015(c) applied for purposes of
resolving her still-pending claim for relief.
Then, in November of 1998, Thomas and respondent entered
into a stipulation settling all issues with respect to Thomas.
Like the earlier settlement with Judith, this stipulation
reflected that an income tax deficiency of $21,711 was due from
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