Brenda J. Clarrk - Page 7

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               Approximately 1 year before the issuance of the notice of              
          deficiency, and presumably motivated by respondent’s examination            
          of the tax returns for the years at issue, petitioner filed Form            
          8857, Request for Innocent Spouse Relief.  In that request,                 
          petitioner claimed as her basis for relief:                                 

               My husband prepares our taxes and I am not informed of any             
               information of ways he prepares these taxes.  I don’t know             
               of expenses or income he claims.  I do not review the taxes            
               he prepares.  He is responsible for any taxes due, past and            
               future.  I know he is being audited for 1998, 2000, and                
               2001, and I have no input into these returns and know                  
               nothing of these results.  Take my liability for any taxes             
               owed off me because I am not responsible for his actions,              
               filings, information, or money.                                        

               Respondent’s action on petitioner’s application for section            
          6015 relief is set out in the notice of deficiency.  In addition,           
          the parties stipulated a copy of the transcript of petitioner’s             
          hearing before the Appeals officer.  That officer considered                
          petitioner’s application for relief under section 6015(b), (c),             
          and (f).  He concluded that petitioner was not entitled to relief           
          under the cited provisions.                                                 
               Generally, married taxpayers may elect to file jointly a               
          Federal income tax return.  Sec. 6013(a).  Each spouse is jointly           
          and severally liable for the entire tax due.  Sec. 6013(d)(3).  A           
          spouse (requesting spouse) may, however, seek relief from joint             
          and several liability under section 6015(b) or, if eligible, may            
          seek an allocation of liability under section 6015(c).  Sec.                






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