- 3 -
Court of competent jurisdiction for an appropriate
order assigning the lottery prize payments to
Woodbridge Sterling Capital, LLC, or its assigns, in
accordance with the terms of the Assignment.
The Certificate of Marital Status was thereafter attached to a
Lottery Prize Assignment Agreement dated September 18, 1997,
between Nichols and Woodbridge Sterling Capital, LLC. Judicial
approval of the lottery assignment was obtained on April 8, 1998.
The sum of $250,000 was paid to Nichols for the assignment during
1998. Petitioner and Nichols filed a joint Federal income tax
return for 1998 but did not report the sale of the lottery rights
on that tax return.
The petition in this case, filed by counsel on July 3, 2002,
asserted:
I disagree that I should be liable for any portion of
the deficiency, as I did not know, or had no reason to
know, of my former husband’s receipt of such proceeds
and his failure to report the same. Facts supporting
my position are more thoroughly described in my
statement in support of Form 8857, Request for Innocent
Spouse Relief, attached hereto as Exhibit A, which I
have filed along with Form 8857.
The attached Form 8857, Request for Innocent Spouse Relief,
prepared by counsel, specifically disclaimed a request for
equitable relief by inserting an “X” to indicate “No” in response
to the question:
Do you have an Underpayment of Tax (that is, tax that
is properly shown on your return but not paid) or
another tax liability that qualifies for Equitable
Relief (see page 4)?
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011