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relief under section 6015, the total unpaid assessed liability
for that year was the same amount, excluding any addition to tax
and interest accrued after November 27, 2000.
As a result of net operating loss carryovers from prior
taxable years, there is no income tax liability due for any of
the taxable years 1994, 1995, 1998, and 1999. However, there are
self-employment tax liabilities for those years of $10,054,
$10,198, $8,935, and $11,582, respectively, all of which are
attributable to Mr. Butner.
On December 31, 2001, petitioner and Mr. Butner filed late
Form 1040 for the taxable year 2000 that showed a tax liability
of $7,807 that was unpaid.
On January 6, 2003, petitioner filed late Form 1040 for the
taxable year 2001 that showed a tax liability of $141, which she
paid at that time.
On January 22, 2001, petitioner timely filed Form 8857,
Request for Innocent Spouse Relief (Form 8857), with respect to
each of the taxable years 1994, 1995, 1998, and 1999. Petitioner
and Mr. Butner resided together during the 12 months preceding
petitioner’s filing her respective Forms 8857 with respect to
those years.
In Form 8857 that petitioner filed for each of the years at
issue, she requested relief under section 6015 from joint and
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Last modified: November 10, 2007