- 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 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008