Pullins v. Commissioner
United States Tax Court
P filed joint tax returns with her husband—timely for tax year 1999 and untimely (in October 2004) for 2002 and 2003. Each return showed a balance due that was not paid when the return was filed. P signed the returns but did not review or question them. She knew or should have known that the taxes reported on them were not fully paid, but she did not know that her former husband had omitted income from one of the returns.
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P filed joint tax returns with her husband—timely for tax year 1999 and untimely (in October 2004) for 2002 and 2003. Each return showed a balance due that was not paid when the return was filed. P signed the returns but did not review or question them. She knew or should have known that the taxes reported on them were not fully paid, but she did not know that her former husband had omitted income from one of the returns. She received no specific benefit from the nonpayment of the taxes. In 2003 the IRS issued a levy notice to P for 1999. P and her former husband separated in late 2004. In…
1Opinion of the Court
Gustafson, Judge:
Petitioner Suzanne Pullins requested section 6015 “innocent spouse” relief from joint liability for income taxes for tax years 1999, 2002, and 2003. 1 The Internal Revenue Service (IRS) denied Ms. Pullins’s request because she did not request relief within two years of the IRS’s first collection activity against her. The IRS then reevaluated Ms. Pullins’s request on the merits and again determined that she was not entitled to relief. Ms. Pullins petitioned this Court, and the issue for decision is whether she is entitled to relief from joint liability under section 6015. We…
2Cases cited18 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
- United States v. RyersonSupreme Court of the United States · 1941
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