Donna M. Sutherland v. Commissioner

155 T.C. No. 6

UNITED STATES TAX COURT DONNA M. SUTHERLAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3634-18. Filed September 8, 2020. In 2010 P’s husband was convicted of tax crimes. As part of a plea agreement he was required to file delinquent returns for 2005 and 2006. Just before his sentencing P signed joint returns with him for those years. In August 2016 P filed a request for innocent spouse relief for 2005 and 2006. During the administrative review process P’s repre- sentative concluded that R’s Appeals officer was incorrectly applying the factors to…