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In response to the notice of deficiency, petitioner filed a
petition with this Court on April 22, 2005. Also on April 22,
2005, petitioner submitted to respondent a Form 8857, Request for
Innocent Spouse Relief (And Separation of Liability and Equitable
Relief), and a Form 12510, Questionnaire for Requesting Spouse.
On July 12, 2005, intervenor filed a notice of intervention
and objected to petitioner’s being relieved of liability under
section 6015.2
OPINION
Petitioner does not dispute the deficiencies and penalties
determined by respondent for the years in issue. Instead, she
seeks relief from joint and several liability under section
6015(c). Respondent agrees that petitioner is entitled to relief
from the entire joint tax liability under section 6015(c).3
However, as previously mentioned, intervenor objects to
petitioner’s being relieved of liability under section 6015.
2 On March 17, 2005, intervenor filed a separate petition
in response to the notice of deficiency. See Wilson v.
Commissioner, docket No. 5184-05S. In his petition, intervenor
sought a redetermination of the deficiencies determined by
respondent and requested relief from liability under sec. 6015.
3 Petitioner also argues, and respondent agrees, that if
she is not entitled to relief under sec. 6015(c), then she is
entitled to relief under sec. 66(c). Because we find petitioner
is entitled to relief under sec. 6015(c), we do not address
petitioner’s alternative claim under sec. 66(c).
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Last modified: November 10, 2007