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Innocent Spouse Relief, requesting relief only under section
6015(b) for the taxable years 1985 and 1986.3 Petitioner’s
request for relief stated in relevant part:
I feel that I should not be liable for a debt to the
IRS that I have been paying since 1992.
* * * Prior to [Mr. Aranda’s] conviction IRS prepared
an audit on our assets for 1985, 1986 and 1987. They
charged us $104,000 (interest and penalty not
included). I was stuck with this debt, due to being
married to him. I did not commit the crime, but yet,
I’m paying. * * * I feel that it is time to set me
free.
On November 16, 2001, respondent issued a notice of
determination that granted petitioner partial relief from joint
and several liability in amounts equal to the additions to tax
for fraud, plus interest, determined with respect to 1985 and
1986, but denied relief with respect to the balance of the 1985
and 1986 assessments.4 The notice of determination specifically
stated: “We’ve determined you are granted partial relief for the
tax years shown above. * * * We find you eligible for relief
under Section 6015(b) in the amount of $8,006.41 plus interest
for 1985 and $22,157.87 plus interest for 1986.”
3In the Form 8857, petitioner also requested relief for
1987. Respondent determined that no relief could be granted
because petitioner had paid the 1987 liability in full.
Petitioner did not petition for review of respondent’s
determination with respect to 1987.
4In a letter dated June 29, 2000, respondent denied
petitioner’s request for relief. Petitioner appealed the
decision administratively, and respondent’s final notice of
determination of Nov. 16, 2001, followed.
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