Kathryn Bernal - Page 3




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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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