- 2 - The cases arise from petitioner’s election to seek relief from joint and several liability under section 6015 for Federal income taxes for 1996 and 1997. Respondent issued to petitioner notices of determination that she is not entitled to relief under section 6015(f). The issue for decision is whether respondent’s determination for each year that petitioner is not entitled to relief under section 6015(f) is an abuse of discretion. Background The stipulated facts and the exhibits received into evidence are incorporated herein by reference. At the time the petitions in these cases were filed, petitioner resided in Anthony, Florida. Petitioner filed her 1996 Federal income tax return jointly with her then husband, Mark J. Martin (husband), on February 12, 1998. Her joint Federal income tax return for 1997 was filed shortly thereafter, on April 15, 1998. Both returns were filed without remittance. It does not appear that petitioner significantly benefited from the failure to pay tax beyond normal support. Petitioner and her husband received a judgment of dissolution of marriage in Illinois on April 27, 2002. Petitioner sent to respondent a Form 8857, Request for Innocent Spouse Relief, dated October 6, 2003.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011