Tammy Debra Martin - Page 3

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               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.                                       






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