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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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Last modified: November 10, 2007