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and all Rule references are to the Tax Court Rules of Practice
and Procedure.
The issues for decision are whether: (1) The Court has
jurisdiction in this proceeding to review the grant by the
Internal Revenue Service (IRS) of innocent spouse relief to
petitioner’s former spouse; and (2) petitioner’s liability should
be limited to 50 percent of the deficiency.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
was filed, petitioner resided in Fall River, Massachusetts.
Petitioner and Jacob Edwards (former spouse) filed a joint
Federal income tax return for 2001. Petitioner and her former
spouse reported $115,297 on line 22, total income. Respondent’s
third party payer reports, however, showed that petitioner
received and failed to report the following items of income:
(1) $440 as compensation for services reported on a Form W-2,
Wage and Tax Statement; (2) $3,339 in unemployment compensation
reported on a Form 1099-G, Certain Government Payments; (3) $12
in interest reported on a Form 1099-INT, Interest Income; and
(4) $6,522 in gross distributions from an individual retirement
account reported on a Form 1099-R, Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
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Last modified: March 27, 2008