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1. I have not earned an income during the entirety of
our seventeen year marriage.
2. I did not sign the 1998 tax return.
3. I did not have any knowledge of what was on the
1998 return.
4. Taxes were always paid by my husband through an
accounting firm, the latest being the firm of
Schiffman, Hughes and Brown in Blue Bell, PA.
5. The reason my husband is not paying the taxes
which are due is to try and gain an advantage in the
divorce proceeding in which we are now engaged.
In response to petitioner’s Form 8857, respondent sent
petitioner a letter dated August 31, 2001 (respondent’s August
31, 2001 letter to petitioner). That letter stated in pertinent
part:
We have made the following determination regarding the
innocent spouse claim you filed for the tax year(s)
shown above [1998].
You are not entitled to equitable relief of liability
for the unpaid balance of your tax under Internal
Revenue Code Section 6015(f).
We are denying your claim because we did not receive an
answer to our request for additional information. If
you furnish the necessary information, we will be glad
to reconsider your request for relief from joint and
several liability. A request for an Appeals hearing
could be denied if you do not submit the enclosed Form
886-A questionnaire.
Sometime between August 31 and October 26, 2001, in response
to respondent’s August 31, 2001 letter to petitioner, petitioner
sent respondent Form 886-A, Innocent Spouse Questionnaire (peti-
tioner’s Form 886-A). In petitioner’s Form 886-A, petitioner
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