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On October 5, 2000, petitioner and Mr. Christman filed a
joint return for 1999, reporting a tax liability of $11,241 which
was paid in full at the time of filing the return. No notice of
deficiency was issued by respondent for taxable year 1999.
Additions to tax were assessed for 1999 under sections
6651(a)(1), (2), and 6654.
Petitioner contends that she did not know taxes were due and
owing for either of the years at issue because she did not review
the 1998 and 1999 returns. Moreover, petitioner claims that Mr.
Christman did not tell her there were any taxes due, and she had
no reason to believe that if there were taxes due Mr. Christman
would not pay them. She admits, however, that at the time she
signed the returns she believed there would be penalties or
additions to tax for not timely filing the returns.
Petitioner and Mr. Christman signed a postnuptial agreement
on August 14, 2000, to stipulate the terms of their divorce.
Neither this agreement nor the divorce decree addressed the
couple’s outstanding tax liabilities.
Petitioner submitted a Form 8857 on March 24, 2004,
requesting relief from joint and several liability for the years
1998 and 1999. Petitioner contends that Mr. Christman handled
their financial affairs after she left the marital home and that,
since 1994, a return preparer prepared all of their income tax
returns. On April 29, 2005, respondent issued a Notice of
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