Mary Ellen Lepordo - Page 3




                                        - 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.                                              







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