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taxes for years 1983, 1984, 1985, 1987, 1990, and 1991. With
respect to the claim for relief under section 6015(b) and (c), we
hold that petitioner is not entitled to relief because there were
no understatements of tax. However, with respect to petitioner’s
claim for equitable relief under section 6015(f), we hold that
respondent’s denial of relief was an abuse of discretion and that
it would be inequitable to hold petitioner liable for the unpaid
taxes.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Tustin, California, at the time she filed her petition.
Petitioner and Darrell T. Foor (Mr. Foor) were married on
March 23, 1983, and separated on May 1, 1989. They filed joint
Federal income tax returns for the years 1983 through 1991. For
the years 1983, 1984, 1985, 1987, 1990, and 1991, petitioner and
Mr. Foor did not fully pay the tax liabilities reported on their
returns. No deficiencies were determined or assessed against
either petitioner or Mr. Foor for these years. Petitioner had a
deficiency for 1988. Petitioner and Mr. Foor were divorced in
1996.
On March 10, 2000, petitioner filed a Form 8857, Request for
Innocent Spouse Relief (And Separation of Liability and Equitable
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