Patricia Barranco - Page 10




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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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