Jeanine T. Foor - Page 2

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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            
                                  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              
               On March 10, 2000, petitioner filed a Form 8857, Request for           
          Innocent Spouse Relief (And Separation of Liability and Equitable           

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