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Petitioner was and is a middle school teacher. Mr. Meadows
was a property tax specialist employed by an energy company. In
March of 2001 petitioner and Mr. Meadows divorced. In June of
2001, respondent determined a deficiency of $5,464 in petitioner
and Mr. Meadows’s income tax for 1999 and issued a notice of
deficiency for a deficiency and a related penalty under section
6662(a). Neither petitioner nor Mr. Meadows petitioned this Court
for a review of respondent’s determination, and respondent
assessed the deficiency and the related penalty.
In August of 2004, petitioner requested innocent spouse
relief for the 1999 tax year pursuant to section 6015(c).
Respondent granted petitioner full relief with respect to the
deficiency in, and addition to, tax that had been assessed.
However, respondent denied relief under section 6015(f) for $1,815
of the unpaid liability shown on the joint 1999 tax return.
Respondent asserts that he is seeking recovery only of that part
of the tax liability shown on the joint return that is
attributable to the earnings of petitioner.
Respondent issued a final notice of determination with
respect to petitioner’s request for innocent spouse relief under
section 6015 in November 2005.
Discussion
Married couples may choose to file their Federal income tax
returns jointly. Sec. 6013(a). Couples filing joint returns are
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Last modified: May 25, 2011