Rhonda K. Juell, a.k.a. Rhonda K. Juell-Podlak, Petitioner, and Glenn M. Evans - Page 9




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               The credits and deductions relating to the Hoyt partnerships           
          claimed on Glenn and petitioner’s joint Federal income tax                  
          returns for the years in issue were eventually disallowed by                
          respondent, resulting in the tax deficiencies determined by                 
          respondent as set forth above.  See supra p. 2.                             
               In or about October 1997, Glenn and petitioner were                    
          separated, and they were divorced in February of 2000.                      
               During 2000, petitioner received her first correspondence              
          from respondent alerting her to the above tax deficiencies that             
          respondent had determined.                                                  
               On August 13, 2001, petitioner acknowledged and entered into           
          a closing agreement with respondent with respect to the above tax           
          deficiencies relating to the Hoyt partnerships for 1987 through             
          1997.                                                                       
               On May 21, 2002, petitioner submitted to respondent a Form             
          8857, Request for Innocent Spouse Relief, under section 6015(b),            
          (c), and (f) with respect to the entire amount of each tax                  
          deficiency for each year in issue.                                          
               On July 16, 2003, respondent issued a preliminary                      
          determination letter denying petitioner’s request for innocent              
          spouse relief.                                                              
               On February 17, 2006, respondent issued a notice of                    
          determination denying petitioner’s request for innocent spouse              
          relief.                                                                     







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