- 9 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007