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Petitioner and Mr. August filed joint tax returns for the
years at issue. The tax returns for 1990 and 1993 were prepared
by a C.P.A. firm, and the 1992 return was prepared by H&R Block.
All of the income reported on these returns came from Mr.
August’s carpet installation business and was reported on
Schedule C, Profit or Loss From Business. The tax returns list
petitioner as a homemaker or housewife. Petitioner signed these
returns. The taxes reported on the returns as due have not been
fully paid. Petitioner’s and Mr. August’s outstanding tax
liabilities for the years at issue are the result of these
underpayments of tax.2
In March 1999, petitioner filed Form 8857, Request for
Innocent Spouse Relief, for each of the years at issue.
Petitioner attached the following statement to each Form 8857:
My ex husband had all the money for our taxes to
be paid before our divorce and instead he used approx
13,000.00 for an attorney for our divorce. He is
living as they say “High on the hog.” Since our
divorce he has bought a new work van all brand new
appliances, fax machine. All I have is a van 79 Dodge
that is valued at 700.00 and does not run most of the
time. I have applied for disability do to post
tramatic stress disorder, obsessive compulsive
disorder, panic attacks, anxiety attacks, and
borderline personality disorder. I’m basically
homeless, and living off family and friends. Please
concider taking me off his account for the years owed.
For I had no part of his business or knowledge he did
not pay off taxes until after our divorce and I filed
my taxes and they went towards his account. I filed a
2 As of Aug. 10, 2000, the remaining liabilities were
$1,670 for 1990, $4,820 for 1992, and $4,656 for 1993.
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