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Federal income tax return showed $9,021 as the “Amount You Owe”,
line 69, but there was no remittance of the tax. The 2000
Federal income tax return showed $15,130 as the “Amount You Owe”,
line 69, but there was no remittance of the tax. Petitioner and
Mr. Nakasu subsequently entered into an installment agreement
with the Internal Revenue Service (IRS) in September 2001 with
respect to their Federal income tax liabilities, and some
payments were made thereunder.
In November 2001, petitioner separated from Mr. Nakasu.
Petitioner and Mr. Nakasu sold the marital home; the sale closed
on February 22, 2002. The “Sellers Closing Statement” contains
petitioner’s handwritten directive to make the proceeds payable
to Mr. Nakasu. Mr. Nakasu did not use the proceeds to pay their
Federal tax liabilities.
Mr. Nakasu filed for divorce in March 2002; the divorce
became final that year. He filed an offer-in-compromise (OIC) in
April 2002, which was rejected in July 2002. In the interim,
petitioner and Mr. Nakasu signed a “Marital Settlement Agreement”
that specifically provided that Mr. Nakasu was to assume
responsibility for and pay their Federal tax liabilities. In
July 2003, however, petitioner discovered that their Federal tax
liabilities were not paid when the IRS contacted her about its
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Last modified: March 27, 2008