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decreased dramatically. Since 1997, petitioner has worked at
several temporary jobs and paid all of her and about 80 percent
of Mr. Wiwi’s expenses. Petitioner’s total monthly household
expenses on behalf of herself and Mr. Wiwi in 1997 and 1998
(including rent, utilities, transportation, food, clothing, and
medical insurance) were about $2,800.
Petitioner had about $5,000 in her savings account in 1996
and $13,500 at the time of trial. She received wages of $65,792
in 1997, $65,338 in 1998, $66,315 in 2000, and $79,000 in 2002.2
Mr. Wiwi’s medical condition worsened, which prevented him
from working in 2000. He had hip replacement surgery in 2000 and
2001.
In 2000, petitioner liquidated an individual retirement
account (IRA) and used the proceeds (about $20,000) as part of a
$33,000 downpayment to buy a $333,000 residence for Mr. Wiwi and
herself. The monthly mortgage payment was about the same as
their previous rent payments. At the time of trial, petitioner
had a section 401(k) retirement account with the American Red
Cross. The record does not indicate the value of that account.
B. Petitioner’s Request for Relief From Joint Tax Liability
On February 2, 1999, petitioner filed Form 8857, Request for
Innocent Spouse Relief (And Separation of Liability and Equitable
Relief), in which she sought relief from joint liability for a
2 The record does not indicate the amount of petitioner’s
income for 1999 and 2001.
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