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Petitioner was married to Gary A. Leissner (Mr. Leissner)
during 1986 and 1987. Petitioner and Mr. Leissner separated on
July 11, 1986. The decree ending the marriage of petitioner and
Mr. Leissner was filed on December 27, 1988, and ordered Mr.
Leissner to pay all Federal income tax liabilities from the date
of the marriage through tax year 1987.
Petitioner and Mr. Leissner filed joint individual income
tax returns for 1986 (the 1986 return) and 1987 (the 1987 return)
on June 5, 1989. No payments were made at the time these returns
were filed. The 1986 return showed a balance due of $44,199,
which was assessed on July 17, 1989. The 1987 return showed a
balance due of $3,822, which was assessed on July 10, 1989.
Pursuant to sections 6321 and 6322, liens in favor of the United
States upon all property and rights to property belonging to
petitioner arose at the time the 1986 and 1987 taxes were
assessed.
On November 18, 1992, respondent notified petitioner that
she was not eligible for so-called “innocent spouse” relief under
section 6013(e), as it then existed, for her tax years 1986 and
1987.
In November 1996, respondent served a notice of levy on
petitioner’s individual retirement account with Merrill Lynch
(the Merrill Lynch account). On December 27, 1996, Merrill Lynch
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