- 5 - tax liabilities, petitioner also made payments to the IRS of $1,533,2 $375, $916, and $510 for 1992, 1993, 1994, and 1995, respectively.3 Petitioner’s Innocent Spouse Claim On November 4, 1999, petitioner filed Form 8857, Request for Innocent Spouse Relief. Petitioner requested equitable relief under section 6015(f) for taxable years 1992, 1993, 1994, and 1995. On July 29, 2000, petitioner prepared and signed a Form 433-A, Collection Information Statement for Individuals. Petitioner also filed a completed Form 886-A, Innocent Spouse Questionnaire. On October 31, 2002, respondent issued a Notice of Determination that denied petitioner’s request for relief for each of the years in issue.4 On February 7, 2003, petitioner’s 2After petitioner’s divorce, she filed her tax returns separately from Mr. Cowdery. The IRS kept petitioner’s refunds from the years following the divorce to offset the prior tax liabilities. The $1,533 payment toward the 1992 liability thus includes refund offsets of $75, $75, $91, and $270, from 1993, 1996, 1997, and 1998, respectively. 3Respondent determined that if petitioner had filed separately rather than jointly with Mr. Cowdery during the years in issue, she would have owed $403, $902, $818, and $509 for each of those years, respectively. When respondent provided petitioner with his determination on Aug. 26, 2000, petitioner promptly obtained money orders for the amounts she would have owed and paid those amounts to the IRS. 4The notice of determination erroneously stated that relief was denied with respect to 1991, 1992, 1993, 1994, 1995, and 1996. Respondent concedes in his pretrial memorandum, however, (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011