Julie C. Nichols, n.k.a. Julie C. Amrein - Page 3

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               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)?                                                   







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