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On August 6, 2001, petitioner submitted to respondent a Form
8857, Request for Innocent Spouse Relief. Attached to the Form
8857 was a letter dated July 21, 2001. In the letter petitioner
states:
I was not aware of the outstanding monies owing until
after my separation and right before my divorce from David
A. Tillotson, which was final on November 22, 2000.
After reviewing my records, I believe the monies owed
for the years 1995, 1997, and 1998 were due to my ex-
husband’s, David A. Tillotson, unemployment and/or self-
employment. I maintained a full-time job in which taxes
were taken out through my employer. Therefore, I do not
feel I am responsible for the taxes owed.
David A. Tillotson was solely responsible for the
paying of these taxes, as he was [responsible for] all of
the household bills. I was not aware that he had not been
paying them. Due to the fact that he was home more than I,
he would always retrieve the mail before I had the
opportunity to do so. Therefore, if there was
correspondence between you and my household, I had no
knowledge of it.
By letter dated August 15, 2001, respondent’s examiner
requested that petitioner complete and submit: (1) A statement
explaining why she believed she qualified for relief; and (2)
Form 886-A, Innocent Spouse Questionnaire.
By letter dated September 8, 2001, petitioner submitted a
statement explaining why she believed that she qualified for
relief and she attached to the letter a completed Form 886-A.
Petitioner stated in her letter, in pertinent part:
I believe I would qualify for relief for the following
reasons. I was unaware that they [the 1995, 1997, and 1998
reported tax liabilities] had not been paid. I was not
responsible for any of the bill paying during my entire
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