- 3 - petitioner hired an accountant to prepare such returns. Joint returns for 1994, 1995, 1996, and 1997 were signed by petitioner on March 14, 2000, and received by respondent on March 21, 2000, and a joint return for 1998 was signed by petitioner on March 14, 2000, and received by respondent on March 20, 2000. The accountant also prepared a joint return for 1999, which petitioner timely filed. The foregoing joint tax returns, collectively referred to as the returns, showed the following amounts due for the respective years: Tax Year Tax Liability 1994 $8,119 1995 7,862 1996 10,037 1997 14,447 1998 19,488 1999 3,740 1Respondent subsequently corrected a math error and increased the balance due for 1997 to $4,873. No portion of the amounts shown as due on the returns was paid at the time of filing. Respondent assessed petitioner’s Federal income taxes based on the returns. The sum of tax, penalties, and interest assessed against petitioner for the years in issue exceeds $115,000. Respondent received from petitioner a Form 8857, Request for Innocent Spouse Relief, and respondent denied that claim for relief. Subsequently, respondent denied a request for reconsideration of respondent’s prior decision and forwarded thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011