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This case is before the Court on petitioner’s petition to
review respondent’s denial of relief under section 6015 with
respect to petitioner’s 1992 and 1993 taxable years.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in St.
Louis County, Missouri, on the date the petition was filed in
this case.
In November 1994, petitioner and her now deceased husband,
Thomas Rooks, filed joint Federal income tax returns for taxable
years 1989 through 1993 on Forms 1040, U.S. Individual Income Tax
Return.1 After applying various payments and credits to the
years 1989 through 1991, all liabilities with respect thereto
have been satisfied. The remaining returns, those for 1992 and
1993, reflected outstanding tax liabilities of $4,872 and $5,294,
respectively. No payment was made with respect to these amounts
at the time the returns were filed.
Mr. Rooks died on August 30, 1996. In November 1996,
petitioner submitted amended returns for each of 1992 and 1993 on
Forms 1040X, Amended U.S. Individual Income Tax Return.
Respondent accepted the changes made by these amended returns,
1Respondent previously had prepared substitute returns for
petitioner and Mr. Rooks for 1989 through 1992. However,
petitioner’s and Mr. Rook’s account was adjusted to reflect the
liabilities shown on the filed returns after they were received
by the Internal Revenue Service.
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