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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...)
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