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the period for assessment had expired with respect to the Moores’
tax years 1987 through 1991.
Petitioner and Mr. Moore executed settlement documents
resolving all of the issues in the cases pending before the
Court. On August 6 and August 11, 2004, the Court entered
decisions in the cases bearing docket Nos. 27274-96 and 1460-03,
respectively, setting forth income tax deficiencies and penalties
for tax years 1992, 1993, 1994, and 1997. On December 28, 2004,
the income tax deficiencies and penalties were assessed against
petitioner for her 1992, 1993, 1994, and 1997 tax years.
On or about August 9, 2005, petitioner, by means of a Form
8857, Request for Innocent Spouse Relief, sought relief from
joint and several liability for her 1992, 1993, 1994, and 1997
tax years.4 Following respondent’s denial, petitioner filed a
petition with this Court instituting this proceeding.
Discussion
Petitioner was a participant in two prior Tax Court
proceedings in which she and Mr. Moore ultimately agreed to
income tax deficiencies and penalties. Based on the Moores’
agreement with respondent, the Court entered decisions for the
income tax deficiencies and penalties. Respondent assessed the
tax and penalties, and petitioner subsequently sought relief from
4 Petitioner did not seek relief for years prior to 1992 due
to respondent’s concession that the period for assessment had
expired with respect to those years.
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