Debra Anne Banderas - Page 2

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          relief from joint and several liability under section 6015.1  The           
          Court has sua sponte raised the question of whether the case                
          should be dismissed for lack of jurisdiction.                               
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.  At the time the petition            
          in this case was filed, petitioner resided in Cape Coral,                   
          Florida.                                                                    
               Prior to his death on November 16, 1999, petitioner was                
          married to Julio C. Banderas (Dr. Banderas).  Petitioner and                
          Dr. Banderas filed a joint Form 1040, U.S. Individual Income Tax            
          Return, for 1997.  Petitioner also filed a joint Form 1040 for              
          1999 as a surviving spouse.  Both returns reflected a balance due           
          and were not accompanied by full payment.                                   
               In June of 2003, petitioner submitted to the Internal                  
          Revenue Service (IRS) a Form 8857, Request for Innocent Spouse              
          Relief.  Petitioner sought relief for underpayments of tax for              
          1997 and 1999 under section 6015(f).  On March 3, 2005, the IRS             
          issued to petitioner a notice of determination denying her                  
          request for section 6015(f) relief.  Petitioner filed a timely              




               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code of 1986, as amended.                                  





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