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Petitioner signed the returns for the years in question.
After petitioner learned of a lien on their house, she began to
file separate returns in 1994.
Mr. Sjodin is a Korean War veteran and has been diagnosed
with a combat-related psychological disorder which caused him to
be secretive and uncommunicative. He did not physically harm
petitioner, but he was not forthcoming to her with information
relating to his business. He continued to provide financial
support to petitioner and their children.
On August 9, 2000, petitioner filed Form 8857, Request For
Innocent Spouse Relief, for the taxable years 1987, 1988, 1990,
and 1992. On April 3, 2003, respondent issued petitioner Letter
3290, Notice of Determination Concerning Your Request for Relief
under the Equitable Relief Provisions of Section 6015(f), stating
that respondent did not allow her request for the years 1987,
1988, 1990, and 1992. Petitioner timely filed with this Court a
petition for determination of relief from joint and several
liability on a joint return.
OPINION
Section 6015(f) permits the Secretary to relieve a spouse of
liability if, taking into account all the facts and
circumstances, it is inequitable to hold the spouse liable for
any unpaid tax or any deficiency (or any portion of either) and
relief is not available under section 6015(b) or (c). The denial
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