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In June 1997, the limited liability company transferred back
to petitioner, for no consideration, the primary residence and
the 5.024-acre Woodland Hill Estates parcel on which it was
situated.
VII. Dr. Barranco’s Release
In September 1997, Dr. Barranco was released from prison
after serving 18 months of his 27-month sentence. He has since
resumed his medical practice. At the time of trial, he resided
with petitioner in their primary residence.
VIII. Petitioner’s Request for Administrative Relief
On or about June 3, 1999, petitioner submitted to respondent
a Form 8857, Request for Innocent Spouse Relief, requesting
relief from joint and several liability for the tax years 1983
through 1992 for additional tax that was not shown on the joint
tax returns that she and Dr. Barranco had originally filed. On
October 20, 2000, respondent issued petitioner a notice of
determination denying the requested relief for the 1988 tax year.
On that same date, with respect to all the remaining tax years at
issue (i.e., 1983-87 and 1989-92), respondent issued petitioner a
notice of deficiency, determining therein that petitioner’s
taxable income for those years should be increased to include the
income diverted through Dr. Barranco’s tax evasion scheme.
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