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Dissolution Agreement” which provides for a settlement of
property rights of the parties. Petitioner has not provided
respondent, respondent’s counsel, or this Court with a copy of
the aforesaid agreement.
On or about April 1, 2002, respondent applied petitioner’s
2001 Federal income tax refund of $2,434 toward petitioner and
Mr. Glaze’s 1995 income tax liability.
On June 3, 2002, petitioner filed a Form 8857, Request for
Innocent Spouse Relief, with respondent, requesting innocent
spouse relief with respect to the 1995 taxable year. On February
25, 2003, respondent issued petitioner a letter advising her of
the preliminary determination denying relief from liability on
the 1995 joint return. On March 29, 2004, respondent sent
petitioner a letter advising her of the final determination
denying her relief from liability for the deficiency, addition to
tax, and penalty for the 1995 taxable year. On April 12, 2004,
petitioner filed a petition with this Court for review of
respondent’s determination denying her request for relief from
joint and several liability with respect to the 1995 tax year.
Discussion
In general, taxpayers filing a joint Federal income tax
return are each responsible for the accuracy of their return and
are jointly and severally liable for the entire tax liability due
for that year. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C.
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