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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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