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items listed in Part 4 of Form 12510 included wages, rent, inter-
est, and dividends. The various expense items listed in Part 4
of Form 12510 included rents, mortgage loans, food, and utili-
ties. The instructions to Part 4 of Form 12510 stated: “If you
completed Part 2, complete this part. If you completed Part 3,
completing this part is optional. However, doing so now may
expedite consideration of your claim.” Pursuant to those in-
structions, petitioner did not complete Part 4 of petitioner’s
Form 12510. That was because, pursuant to the instructions to
Part 2 of Form 12510, petitioner was not required to, and did
not, complete Part 2 of petitioner’s Form 12510 since petitioner
is not seeking relief under section 6015 with respect to an
underpayment of tax for her taxable year 1982. Petitioner is
seeking relief under section 6015 with respect to an understate-
ment of tax for that year.
Petitioner attached Form 12507, Innocent Spouse Statement
(petitioner’s Form 12507), to petitioner’s Form 8857. An attach-
ment to petitioner’s Form 12507 (petitioner’s attachment to
petitioner’s Form 12507) stated in pertinent part:
In 1964, Ernest [Mr. Korchak] accepted a position
with Halcon International, Inc., in Little Ferry, New
Jersey, and the couple [petitioner and Mr. Korchak]
moved to Hackensack. Their first child was born that
year. Helen [petitioner] discontinued her work outside
the home to be a full-time mother and homemaker. In
1967, the couple’s second child was born and, in 1969,
their third and final child was born. During the years
between 1964 through 1976, Helen was a full-time home-
maker. In 1969, the Korchak’s moved from Hackensack,
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