- 2 - are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. This case arises from a request for relief from joint and several liability under section 6015(f) with respect to petitioner’s unpaid joint tax liabilities for 1999 and 2000. No notices of deficiency were issued. Petitioner requested relief by filing Form 8857, Request for Innocent Spouse Relief (And Separation of Liability and Equitable Relief). The issues for decision are whether petitioner is entitled to relief from joint and several liability under section 6015(b), (c), or (f) for each year. Background Some of the facts have been stipulated and are so found. The stipulation of facts and the exhibits received into evidence are incorporated herein by reference. At the time the petition was filed, petitioner resided in California. Petitioner is a high school graduate who has worked in real estate and as a “personal banker” for Bank of America. Petitioner married Masafumi Nakasu in 1991. They started having marital problems in 1998 after the birth of their second child. Petitioner and Mr. Nakasu also started having financial troubles; they filed for bankruptcy and received a discharge in April 1998. Petitioner and Mr. Nakasu filed joint Forms 1040, U.S. Individual Income Tax Return, for 1999 and 2000. The 1999Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008