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“any other marital debt not specifically included” in the divorce
decree. He was to pay monthly child support of $135; he was not
required to pay petitioner any spousal support.
Mr. Scott remarried after he was divorced from petitioner.
Petitioner married Mr. Smith in 2002. Shortly after they were
married, Mr. Smith’s employer went out of business, and Mr. Smith
began collecting unemployment compensation. Petitioner has been
employed as a receptionist for a publishing company. She is paid
$9.60 per hour for 32 hours a week.
On August 9, 2002, petitioner filed a Form 8857, Request for
Innocent Spouse Relief, seeking relief under section 6015(b),
(c), and (f) from liability for taxes owed for 1990 through 1995.
In accordance with the instructions to Form 8857, petitioner
attached a statement explaining why she believed she was entitled
to section 6015 relief. She stated:
As of January 8, 2001, I was divorced from David
R. Scott. He worked for a CPA Accounting firm in
Oakland, California, and he took care of all of the
financial matters in our family. I had complete trust
in him [sic] doing the books and taking care of these
matters. During this twenty-five year marriage I never
questioned the totals or figures of our Income Taxes or
references to the taxes. In tax matters, my knowledge
was, and is very limited and so when he said he would,
“take care of it”, I had no reason to believe
otherwise.
During part of this marriage we conducted a home
based business. At the opening of the business he
agreed that his part would be to keep record of the
accounting details, while I was busy with all other
aspects of running this business. During this period
of time, with the business in our home, he indicated to
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Last modified: November 10, 2007