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throughout their marriage, and that she was told where to sign
and never looked at the return. On April 10, 2003, petitioner
filed a questionnaire for taxpayers requesting section 6015
relief. In that questionnaire petitioner detailed her claim and
requested a refund of her overpayments which were used to offset
the Easlers’ 1997 tax liability.
In a letter dated March 17, 2003, respondent’s innocent
spouse unit at the Cincinnati, Ohio, Service Center (innocent
spouse unit) notified intervenor that petitioner had requested
section 6015 relief with respect to taxable year 1997 and
requested that intervenor complete and submit Form 12507,
Innocent Spouse Statement, and Form 12508, Innocent Spouse
Information Request. Intervenor submitted the completed
requested forms by May 2, 2003. On Form 12508 he stated: That
he and petitioner filled out their 1997 tax return together; that
petitioner was fully aware of everything stated on, and omitted
from, the return; that petitioner wanted to omit intervenor’s
wages from the return in order to obtain a larger refund; and
that the divorce decree requires petitioner and intervenor to
share equally their marital debt.2
In a letter dated October 21, 2003, respondent’s innocent
spouse unit notified petitioner that her claim for section 6015
2We do not address intervenor’s contentions because we
conclude, for reasons stated below, that petitioner is ineligible
for relief regardless of intervenor’s contentions and testimony.
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Last modified: May 25, 2011