Janice L. Cardiff, f.k.a. Janice Dunn, Petitioner, and Stephen Dunn, Intervenor - Page 3

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          discretion in determining that petitioner qualified for full                
          equitable relief under section 6015(f).                                     
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioner resided in Oceanside, California, at the              
          time she filed her petition.  Intervenor resided in Vista,                  
          California, at the time of the filing of the Notice of                      
          Intervention in this case.                                                  
               Petitioner and intervenor, while married, jointly filed a              
          Form 1040, U.S. Individual Income Tax Return, for 1994.                     
               The 1994 return reflects a balance due of $4,531.  Neither             
          petitioner nor intervenor paid this amount when the 1994 return             
          was filed.  A portion of the amount plus statutory accruals                 
          remains unpaid.                                                             
               Petitioner and intervenor legally separated sometime during            
          1995, and were divorced on November 20, 1996.  Neither the                  
          divorce decree nor the marital separation agreement allocates or            
          addresses responsibility for payment of the 1994 income tax                 
          liability.                                                                  
               In 1996, petitioner filed a Chapter 7 bankruptcy petition,             
          but the 1994 income tax debt was not discharged because the 1994            
          tax return was due within the 3-year period prior to the filing             
          of the petition.                                                            
               On May 29, 2001, petitioner filed a Form 8857, Request for             
          Innocent Spouse Relief, seeking relief from liability for the               






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