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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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