- 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 NextLast modified: November 10, 2007