Arlene C. Ogonoski - Page 6

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               On November 1, 2000, petitioner filed Form 8857, Request for           
          Innocent Spouse Relief, with respondent regarding taxable years             
          1972 through 2000.  On this form, petitioner requested relief               
          under section 6015(b) and (f), claiming that she had an                     
          “understatement of tax” and “underpayment of tax”, respectively.            
               On November 1, 2000, when petitioner filed her request for             
          relief under section 6015, there were no outstanding tax                    
          liabilities due from petitioner for taxable years 1972 through              
          1988.  Petitioner stated that Mr. Ogonoski had paid, apparently             
          out of his own separate funds, all of the outstanding taxes,                
          interest, and penalties for taxable years 1972 through 1988.                
               When petitioner filed her request for relief under section             
          6015 with respondent, there were outstanding tax liabilities                
          resulting from balances due on her and Mr. Ogonoski’s joint                 
          returns for taxable years 1989 through 1999.  In her request for            
          relief, petitioner acknowledged:  “I have been told if I file               
          separately I would not be in this predicament.  However I believe           
          if you are married you file jointly”.                                       
               In workpapers dated May 22, 2001, respondent’s examiner                
          proposed to deny petitioner relief under section 6015(b) and (f)            
          for all of petitioner’s outstanding tax years.                              
               On June 25, 2001, petitioner filed a Form 12509, Statement             
          of Disagreement, in which she appealed the examiner’s proposed              
          determination with respondent’s Appeals Office and requested                
          relief under section 6015 for her 1989 through 1997 tax years.              




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