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Background
Petitioner filed for divorce from her spouse in May 1998.
It is not clear from the record whether or when the divorce was
finalized.
Petitioner filed individual Federal income tax returns as
married, filing separate, for the taxable years 1993, 1994, 1995,
and 1996 in June 1998. Petitioner alleges that she filed the
returns after she learned of an outstanding Federal income tax
liability upon filing for bankruptcy under chapter 13 in or
around June 1998.
In a notice of deficiency dated October 26, 1998, respondent
determined that petitioner was liable for deficiencies of $4,483
and $6,749 for the taxable years 1993 and 1994 and failure to
file additions to tax under section 6651(a)(1) of $1,121 and
$1,687, respectively. In a notice of deficiency also dated
October 26, 1998, respondent determined that petitioner was
liable for deficiencies of $5,704 and $7,453 for the taxable
years 1995 and 1996 and failure to file additions to tax under
section 6651(a)(1) of $1,426 and $1,863, respectively. The
notices of deficiency indicate that the adjustments to income
resulted from a “community property split”. No petition was
filed with this Court in response to the notices of deficiency.
On June 29, 1999, petitioner filed with respondent Form
8857, Request for Innocent Spouse Relief, requesting relief from
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Last modified: May 25, 2011