Yvonne C. Lopez - Page 5

                                        - 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