- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011