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Following her divorce, petitioner’s Federal income tax
returns were timely filed. With the exception of 2001, all of
the taxes shown on those returns were paid timely.4
By letter dated April 1, 2002, respondent notified
petitioner that the 1995 tax liability remained unpaid.
On April 6, 2002, petitioner submitted to respondent a Form
8857, Request for Innocent Spouse Relief, in which she requested
section 6015 relief from the unpaid portion of her 1995 Federal
income tax liability. According to the form, petitioner seeks
only “equitable relief” from that liability. On a questionnaire
submitted after her request, petitioner listed her total monthly
income and living expenses as $3,000 and $2,968, respectively.5
On November 15, 2002, respondent sent a preliminary letter
to petitioner notifying her that she was not entitled to relief
under section 6015. In December 2002, petitioner submitted
to respondent a Form 12509, Statement of Disagreement. On
4 Petitioner testified, and the record does not reflect
otherwise, that she entered into an installment agreement with
the IRS with respect to her unpaid taxes for the 2001 tax year.
As a result of this installment agreement, petitioner’s 2001 tax
liability was paid in full in March 2003.
5 In a subsequent submission to respondent, petitioner
listed her total monthly income and living expenses as $3,181 and
$3,024, respectively. Petitioner also provided copies of several
medical bills for herself and her son which totaled $1,051. On
the basis of petitioner’s 2002 tax return and the limited
information she provided, respondent determined that petitioner’s
total monthly income and allowable living expenses were $3,734
and $3,436, respectively.
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Last modified: May 25, 2011