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through 1998 were not paid. At the time petitioner signed the
1992 through 1998 Forms 1040, U.S. Individual Income Tax Return,
she knew that the balances due would not be paid because she and
Mr. Griffin were in bankruptcy and had no funds with which to pay
the taxes. There are still currently balances due on
petitioner’s and Mr. Griffin’s joint Federal income tax
liabilities for the 1992 through 1998 tax years.
Petitioner was not employed during the 1992 through 1998 tax
years, except for a period of approximately 2 weeks to 2 months.
Petitioner reported no income attributable to services she
performed on the Forms 1040 she and Mr. Griffin filed for the
1992 through 1998 tax years.
Petitioner had actual knowledge that Mr. Griffin earned
income during the 1992 through 1998 tax years. Petitioner was
not abused by Mr. Griffin. No assets were transferred between
petitioner and Mr. Griffin as part of a fraudulent scheme, and no
disqualified assets were transferred to petitioner by Mr.
Griffin.
On April 11, 2003, petitioner filed a Form 8857, Request for
Innocent Spouse Relief, with respondent, requesting innocent
spouse relief with respect to the 1992 through 1998 tax years.
On December 19, 2003, respondent sent petitioner a letter
advising her of the determination denying relief from liability
on the 1992 through 1998 joint returns. On March 10, 2004,
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