Patricia H. Devlin - Page 4

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          Collins.  At the time that she signed the 1999 return, petitioner           
          was aware of the financial difficulties with Collins’s business             
          and did not know how Collins would be able to pay the tax                   
          liability stated on the return.  Petitioner’s father died in                
          November 2000.                                                              
               At some point after his divorce from petitioner, Collins               
          filed for bankruptcy.  In late 2003, petitioner completed,                  
          signed, and filed with the Internal Revenue Service Form 8857,              
          Request for Innocent Spouse Relief, and Form 12510, Questionnaire           
          for Requesting Spouse.  On Form 12510, petitioner reported net              
          income exceeding specified expenses by more than $1,000 per                 
          month.  Petitioner’s request for relief was denied in full on               
          March 31, 2005.                                                             
               Generally, married taxpayers may elect to file a joint                 
          Federal income tax return.  Sec. 6013(a).  When a husband and               
          wife elect to file a joint Federal income tax return, they are              
          jointly and severally liable for the entire tax due on that                 
          return.  Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C. 276,             
          282 (2000).  However, section 6015 provides for relief for a                
          requesting spouse from joint and several liability in certain               
          circumstances.  Because this case involves only an underpayment             
          of tax shown on a return, only section 6015(f) applies.  Petrane            

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