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salary and from which they paid household bills and some business
bills. Petitioner had complete access to the joint accounts,
reviewed monthly bank statements, and balanced the joint
checkbook to the bank statements.
Petitioner and Mr. Puckett filed for bankruptcy under
chapter 7 of the Bankruptcy Code on October 4, 2001, and they
received a discharge on February 14, 2002.
On October 29, 2001, petitioner and Mr. Puckett filed a
delinquent joint Federal income tax return for the taxable year
2000 reporting tax due of $10,027.2 The amount due was solely
attributable to Mr. Puckett’s income calculated as an $8,893
self-employment tax liability plus an $823 tax on an individual
retirement account distribution. They did not remit payment with
their return.
On November 26, 2001, respondent assessed the tax, less
income tax withholding and estimated tax payments, plus the
applicable penalties and interest.
Petitioner submitted to respondent Forms 8857, Request for
Innocent Spouse Relief, dated September 13, 2002, and November 6,
2002. On June 3, 2003, respondent’s Examination Division denied
petitioner’s request for relief from joint and several liability.
2 On the return, petitioner and Mr. Puckett reported total
tax of $9,716 on line 57 and total payments of $44 on line 65.
The return also reported an “estimated tax penalty” in the amount
of $355.
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Last modified: May 25, 2011