Cimberly Catherine Clarke-Lewis - Page 3




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          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 1999                  







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