- 4 -
liability for 1997, that her wages were being garnished to pay
the 1997 tax liability, and that petitioner and Mr. Crouch could
not pay the amounts due for 1998 and 1999.
On or about March 20, 2001, petitioner filed a Form 8857,
Request for Innocent Spouse Relief, requesting equitable relief
under section 6015(f). Along with the Form 8857, petitioner
submitted a letter explaining why she thought she was entitled to
equitable relief. The letter stated in part:
Our tax matters have always been handled by David. * *
* I had no knowledge that our Joint tax returns for tax
years 1997, 1998 and 1999 were not timely filed. I
became aware of this situation, last summer when * * *
[a revenue officer] placed her business card in the
door of our residence. I had no knowledge until this
happened; and then I only knew Dave was behind for
1997. When the Service levied my wages in December
2000; I became aware of the unfiled 1998 & 1999 tax
returns.
The underpaid taxes * * * are attributable solely to
David’s business * * * I have never been involved in my
husband’s business * * *. David maintained the books
and records of his business.
David & I retained the law firm of Roni Lynn Deutch, to
negotiate a payment plan on the delinquent tax returns.
I was not offered nor received counsel with respect to
my option of filing separately; from David, for the
unfiled years. * * *
If I had received knowledge of the tax situation by my
husband, our tax preparer, or Roni Lynn Deutch I would
have elected to file separate federal & state of Ohio
tax returns for 1997, 1998 & 1999.
On August 17, 2001, respondent notified petitioner that the Form
8857 had been received and requested additional information.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007