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D. Forms 8857
On December 21, 2000, petitioner Yvonne E. Thurner filed
with respondent Form 8857, Request for Innocent Spouse Relief,
requesting relief from joint and several liability under section
6015 with regard to the taxable years 1980, 1981, 1990, and 1992.
On August 2, 2001, petitioner Scott P. Thurner filed with
respondent Form 8857 requesting relief from joint and several
liability under section 6015 with regard to the taxable years
1980, 1981, 1990, and 1992. Respondent did not respond to
petitioners’ claims for relief from joint and several liability.
E. Petitions
On August 10, 2001, petitioner Yvonne E. Thurner filed with
the Court a petition for determination of relief from joint and
several liability on a joint return with regard to her tax
liabilities for 1980, 1981, 1990, and 1992. On February 15,
2002, petitioner Scott P. Thurner filed with the Court a petition
for determination of relief from joint and several liability on a
joint return with regard to his tax liabilities for 1980, 1981,
1990, and 1992. Although the petitions are not entirely clear,
it appears that petitioners claim that they are entitled to
relief under section 6015(b) and (f).2
2 The record indicates that, at the time the petitions were
filed in these cases, petitioners were not divorced or legally
separated and that petitioners continued to live together.
Therefore, petitioners would not qualify for relief from joint
and several liability under sec. 6015(c).
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