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Petitioner and Mr. Izzi started filing separate income tax
returns in 1994.
In 1997, petitioner and Mr. Izzi divorced.
Petitioner overpaid her income taxes for 1998, 1999, 2000,
and 2001 in the amounts of $2,871, $3,268, $1,801, and $1,422,
respectively. Petitioner received a refund of her 2000 tax of
$1,801.
On March 14, 2001, petitioner mailed respondent a Form 8857,
Request for Innocent Spouse Relief (And Separation of Liability
and Equitable Relief). Petitioner solely requested equitable
relief for 1992. Petitioner claimed to have paid $5,189.62 of
the $7,881 owed for 1992. Petitioner also noted a permanent
restraining order, issued by a local court, against Mr. Izzi
relating to a felony committed against her family.
On February 13, 2002, Appeals Officer Therese A. Xavier
wrote to petitioner in response to a telephone message she
received from petitioner on February 8, 2002. Ms. Xavier
attached a copy of petitioner’s 1992 nonmaster file transcript
detailing assessments (including interest), payments, and
petitioner’s balance for 1992 (1992 nonmaster file transcript).
Petitioner’s 1992 nonmaster file transcript shows petitioner
had a balance due, including interest, of $2,182.26 as of
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