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FINDINGS OF FACT
On May 31, 1996, petitioner and intervenor were married in
Norway. From January 2001 until August 2002, petitioner attended
college in Norway, where she studied electrical engineering.
From September 2002 until September 2003, petitioner lived and
worked in California. During 2001 and 2002, Mr. Jahic owned and
operated a coffee shop and a night club in Missouri. In
addition, he maintained the books and records relating to the
businesses. Petitioner did not participate in, and was not
familiar with, the day-to-day operations of the businesses.
Petitioner and Mr. Jahic filed joint Federal income tax
returns relating to 2001 and 2002. Mr. Jahic prepared and signed
the returns on behalf of petitioner, but he did not show the
returns to, or discuss the items of income with, petitioner. On
May 8, 2004, petitioner and Mr. Jahic’s marriage was dissolved.
On December 24, 2004, petitioner timely sent respondent a
Form 8857, Request for Innocent Spouse Relief, relating to 2001
and 2002. On March 22, 2005, respondent sent petitioner and Mr.
Jahic a notice of deficiency relating to 2001 and 2002.
Respondent determined deficiencies and section 6662(a) accuracy-
related penalties relating to 2001 and 2002. On June 27, 2005,
1(...continued)
the Internal Revenue Code in effect for the years in issue.
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Last modified: November 10, 2007