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The Murrays were divorced in June 1998. The property
settlement, which was included in the Murrays’ divorce decree,
provided, inter alia, that intervenor was solely responsible for
paying their community debts. This included their joint tax
liability.
After her divorce from intervenor, petitioner had custody of
her and intervenor’s two children, found new employment, married
Mark Van Arsdalen (Mr. Van Arsdalen), and had a third child.
Petitioner has complied with tax laws since 1997.
D. Petitioner’s Request for Relief Under Section 6015
On April 3, 2001, respondent received petitioner’s Form
8857, Request for Innocent Spouse Relief, in which petitioner
sought relief from joint liabilities of tax under section
6015(b), (c), and (f) for 1989 and 1991 through 1996. Respondent
granted petitioner’s request for relief for 1989 and 1991 on
December 17, 2001. On October 24, 2003, respondent determined
that petitioner was not qualified for relief under section 6015
for 1992 through 1996.
E. Petitioner’s Finances
In May 2005, petitioner and intervenor owed tax, penalties,
and interest in the amount of $110,114.72. At that time,
petitioner was about 47 years old and had about $63,000 in her
section 401(k) retirement plan account and about $45,000 in
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