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Petitioner and Mr. Hopkins reported, but did not pay, taxes
due of $1,571 and $3,326 on their joint income tax returns for
1988 and 1989, respectively. Respondent assessed those amounts.
On May 24, 1999, petitioner filed with respondent a Form
8857, Request for Innocent Spouse Relief, with respect to her
1982, 1983, 1984, 1988, and 1989 joint tax liabilities. On
January 8, 2001, petitioner filed a petition for relief from
joint and several liability with this Court. At the time the
petition was filed, respondent had not made a determination with
respect to petitioner’s request.8
OPINION
A. Tax Liabilities for 1982, 1983, and 1984
Petitioner claims that she is entitled to relief from joint
and several liability under section 6015(b), (c), or (f) for the
tax liabilities attributable to the disallowance of the Far West
Drilling partnership deductions and the disallowance of the NOL
carryforward deductions for 1982, 1983, and 1984.
8Pursuant to sec. 6015(e)(1)(A), a petition may be filed
with this Court after the passage of 6 months from the date the
taxpayer elected sec. 6015 relief if the Commissioner has made no
determination regarding the election.
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