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tax and interest would be paid if their request for abatement was
denied.
On August 7, 1998, the IRS denied petitioner’s and
intervenor’s request for abatement. As of March 2, 2001, the
additions to tax and interest totaled more than $336,000. As of
the time of trial on February 2, 2004, the additions to tax and
interest remained unpaid.
Petitioner’s and Intervenor’s Divorce Proceedings
On April 15, 1998, petitioner and intervenor separated, and
petitioner filed a petition for dissolution of marriage.
Petitioner’s and intervenor’s marriage was dissolved by Final
Decree of Dissolution of Marriage filed on November 1, 1999. A
Final Judgment as to Equitable Distribution, Alimony and Child
Support and Visitation (final judgment) was filed on August 15,
2000. Among other things, the final judgment declared intervenor
solely responsible for payment of the additions to tax and
interest that had been determined “or may accrue” with respect to
the tax liabilities reported on petitioner’s and intervenor’s
joint income tax returns for 1990 through 1995.
On or about September 11, 2000, intervenor filed an appeal
with respect to the final judgment. On or about July 10, 2002,
the final judgment was reversed in part. An Amended Final
Judgment as to Equitable Distribution, Alimony and Child Support
and Visitation (amended final judgment) was filed on February 24,
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