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On October 31, 1999, Mr. and Mrs. Stroud separated and
commenced dissolution proceedings. On July 21, 2000, petitioner,
pursuant to section 6015(f), filed a Form 8857, Request for
Innocent Spouse Relief, for joint income tax liabilities relating
to 1994 and 1996 through 1998. In October of 2000, Mr. and Mrs.
Stroud sold the residence and paid their 1994 and 1996 tax
liabilities.
On March 25, 2002, respondent granted petitioner’s request
for innocent spouse relief relating to 1994 and 1996 but denied
her relief relating to 1997 and 1998. Respondent, however, did
not grant petitioner’s request for refunds of $10,777 and $34,367
that constituted one-half of the payment applied to the 1994 and
1996 income tax liabilities, respectively. On April 4, 2002,
petitioner appealed respondent’s decision denying her a refund
relating to 1994 and 1996. On October 13, 2004, respondent’s
Appeals officer denied petitioner’s appeal regarding her refund
request but upheld respondent’s determinations to grant
petitioner equitable relief relating to 1994 and 1996.
On January 18, 2005, while residing in Fountain Valley,
California, petitioner filed her petition seeking a
redetermination of respondent’s denial of a refund relating to
1994 and 1996.
OPINION
We may exercise jurisdiction only to the extent authorized
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Last modified: May 25, 2011