Judith A. Madden - Page 7

                                        - 7 -                                         
              Petitioner and Mr. Sturges filed an offer-in-compromise in              
         an attempt to compromise their 2000 tax liability for $1 on                  
         October 22, 2001.  On January 17, 2002, petitioner informed the              
         revenue officer who was considering the offer-in-compromise that             
         she had unsuccessfully tried to refinance the residence in order             
         to raise the money to pay the tax.  On January 23, 2002, with the            
         offer-in-compromise still under consideration, petitioner and Mr.            
         Sturges borrowed $115,000, increasing the mortgage debt to                   
         $477,000.  They used the borrowed funds to pay the debt on their             
         credit cards and their daughter’s college tuition.  The IRS                  
         rejected the offer-in-compromise on or about April 23, 2002.                 
              On June 19, 2002, petitioner filed a Form 8857, Request for             
         Innocent Spouse Relief, and petitioner and Mr. Sturges filed                 
         separate offers in compromise offering to compromise their 2000              
         tax liability for $200 and $1,000, respectively.  The offers in              
         compromise were rejected on August 19, 2002.                                 
              On August 9, 2002, respondent sent petitioner a letter                  
         acknowledging receipt of petitioner’s request for innocent spouse            
         relief and providing information on the claim process.                       
         Respondent included Publication 971, Innocent Spouse Relief,                 
         which explained the requirements for relief in detail, and a                 
         questionnaire to be completed by petitioner.  The letter also                
         informed petitioner that respondent was required to inform Mr.               
         Sturges that petitioner had requested relief and that a separate             

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011