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their bank statements, petitioner discovered that Mr. Flowers had
hidden some withdrawals from her during the year.
Respondent received from petitioner a Form 8857, Request for
Innocent Spouse Relief. Petitioner also submitted to respondent
a completed Form 12510, Questionnaire for Requesting Spouse, in
which she provided a list of her monthly expenses. Those
expenses total $4,185 and are as follows:
Rent $875
Food 360
Utilities 200
Telephone 100
Auto Payments 585
Auto insurance 71
Auto fuel & repairs 200
Medical 100
Clothing 100
Credit card 300
Braces & eyeglasses 188
Tutoring 956
Gas 150
Respondent determined petitioner was not entitled to relief
from joint and several liability for the understatement for tax
year 2000 pursuant to section 6015 because petitioner knew or had
reason to know of the item causing the understatement of tax, and
the item causing the understatement was partly attributable to
petitioner.
Discussion
Generally, married taxpayers may elect to file a joint
Federal income tax return. Sec. 6013(a). After making the
election, each spouse is jointly and severally liable for the
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