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petitioner did not. Petitioner did, however, intend to file a
joint return. On this return, they reported, but failed to pay,
an income tax balance of $823.
Throughout their marriage, Mr. Bracy abused petitioner both
physically and emotionally, and on August 20, 2002, they
divorced. Pursuant to the divorce decree, petitioner and Mr.
Bracy were each responsible for one-half of their 2001 tax
liability. In a notice of deficiency dated September 3, 2002,
respondent determined that petitioner and Mr. Bracy were liable
for $6,517 of tax and a $947 section 6662(a) accuracy-related
penalty relating to 2000. Petitioner, on October 7, 2002, paid
$411.50 (i.e., half of the 2001 outstanding liability).
On May 23, 2003, petitioner timely sent respondent a Form
8857, Request for Innocent Spouse Relief, relating to 2000 and
2001. On August 10, 2005, petitioner untimely filed her
individual income tax return relating to 2003. She had refrained
from filing the return while trying to settle outstanding issues
relating to her and Mr. Bracy’s 2000 and 2001 tax liabilities.
On October 20, 2005, respondent issued petitioner a notice
of determination denying her request for innocent spouse relief
relating to both years. Respondent denied the 2000 request
because he determined that petitioner knew or had reason to know
of the source of the understatement, benefited from the income,
and would not suffer economic hardship. Respondent denied the
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