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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 requests for innocent spouse relief
under section 6015(f) with respect to petitioner’s tax
liabilities for 1996 and 1998 through 2002. No notices of
deficiency were issued except for 2000.1 Petitioner filed Forms
8857, Request for Innocent Spouse Relief (And Separation of
Liability and Equitable Relief), seeking equitable relief under
section 6015(f) for each year. Respondent determined that
petitioner was not entitled to relief under section 6015(f) for
1996, 1998, 1999, 2001, and 2002. With respect to 2000,
petitioner requested relief of $3,971.88; respondent granted
partial relief of $3,267 under section 6015(c) but found
petitioner liable for $704.88.2 The issues for decision are
whether respondent: (1) Correctly denied relief as to the
$704.88 under section 6015(c) for 2000; and (2) abused his
discretion when he denied petitioner’s request for innocent
spouse relief for 1996 and 1998 through 2002 under section
6015(f).
1 Petitioner and Mr. Lepordo did not file a petition with
the Court, and respondent assessed the $17,701 deficiency.
2 Respondent represents that he determined that petitioner
did not have knowledge of Mr. Lepordo’s gambling income and
pension distributions in 2000.
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Last modified: March 27, 2008