- 2 - 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 EquitablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011