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‘90 concerning annuities.
3. I.R.S. granted ex-wife inn. spouse relief
on or about 9-28-93. I.R.S. Rep. wrote me on
2-14-95 informing me they were still trying
to collect from ex, when this was not true.
IRS verbally informed me of granting inn.
spouse relief to my ex in Dec. ‘98. This was
the first I was notified of this.
4. The annuity in question was cashed in in
early 1990 & benifited ex-spouse.
5. 1990 return was a joint return & ex is
equally liable.
6. Clifford W Miller has paid $1683.00 to
date on this 1990 return.
6. In the event the court does not rule favorably on
the petitioner’s request, petitioner prayerfully
requests that his liability be limited to the
unpaid portion of the $2691.00 original tax with
no penalties or fines included. [Reproduced lit-
erally.]
In the answer to the amended petition, respondent alleged,
inter alia, that “on or about May 29, 1998, respondent determined
that Ms. Bacon qualified as an innocent spouse, under the provi-
sions of I.R.C. � 6013(e), with respect to the 1990 income tax
deficiency”.
Discussion
A summary adjudication may be made that disposes of all of
the issues in controversy if, inter alia, it is shown that there
is no genuine issue as to any material fact with respect to those
issues. See Rule 121(b). We conclude that there is no genuine
issue as to any material fact regarding the issues raised with
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