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Petitioner and intervenor separated in September 1997 and
were divorced on February 9, 1998. Petitioner was awarded
custody of their son, and intervenor was allowed visitation
rights. The divorce decree made no provision for any joint
liabilities, including any Federal income tax liabilities.
On February 26, 1999, respondent sent both petitioner and
intervenor a notice of deficiency determining a deficiency in
their 1996 Federal income taxes in the amount of $1,564. The
deficiency was based on intervenor’s unreported income and the
disallowance of most of the claimed earned income credit.
Neither petitioner nor intervenor filed a petition with the
Court to contest their 1996 tax deficiency.
On March 4, 1999, petitioner submitted to respondent a Form
8857, Request for Innocent Spouse Relief, requesting section 6015
relief. On April 7, 2000, respondent sent a letter to petitioner
requesting that he complete a questionnaire to assist in
respondent’s determination. Petitioner did not respond to the
questionnaire or otherwise provide respondent with any of his
financial information.
On July 11, 2002, respondent issued a notice of final
determination advising petitioner that he was not entitled to
relief under section 6015.
At the time of trial in May 2003, petitioner was employed as
an aircraft worker at Robbins Air Force Base earning an annual
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