Nancy A. Sjodin - Page 3

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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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