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driving for TDI for 6 or 7 months in 1997, at the time their 1997
joint Federal income tax return (the joint return) was filed,
petitioner knew only that he worked at least 3 months for TDI
during that year.
In 1997, petitioner and Mr. Tice began experiencing serious
marital difficulties. On January 26, 1998, petitioner prepared
the joint return and attached Forms W-2, Wage and Tax Statement,
from Prestige and Kelly. When petitioner asked Mr. Tice for a
Form W-2 from TDI, Mr. Tice told her that he would “take care of
it”.
A Form 1099 was not sent to petitioner’s residence, and the
joint return did not include compensation TDI paid to Mr. Tice.
In 1999, respondent notified petitioner of proposed changes to
the joint return relating to Mr. Tice’s compensation from TDI
(i.e., $9,133) and a resulting disallowance of the claimed earned
income tax credit (i.e., $961). Petitioner subsequently filed a
Form 8857, Request for Innocent Spouse Relief, in which she
contended that, at the time the return was filed, she was not
aware that Mr. Tice had self-employment income from TDI.
By letter dated February 8, 2000, respondent notified Mr.
Tice of petitioner’s contention that she should be relieved from
joint and several liability pursuant to section 6015 (section
6015 relief). In his response dated February 15, 2000, Mr. Tice
contended that petitioner was not entitled to section 6015
relief.
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Last modified: May 25, 2011