Stephenson v. Commissioner
United States Tax Court
T.C. Memo. 2011-16 (2011)
Facts
Valarie Stephenson (plaintiff) married Sean Stephenson in 1991. After the wedding, Valarie dropped out of high school. Sean began verbally and physically abusing Valarie. Sean also controlled the couple’s finances and kept all financial documents locked away from Valarie. In 1999, the Stephensons filed a joint income-tax return showing an income of approximately $215,000 and approximately $78,000 taxes owed. The Stephensons did not include payment with the return. Sean continued abusing Valarie until Valarie left in 2007. The Stephensons were divorced in 2008. Valarie lived in a friend’s basement and moved between jobs. She could not receive unemployment benefits, and Sean failed to pay spousal maintenance. When Valarie filed her own income-tax return after leaving Sean, she learned of the unpaid joint tax liability from 1999. Valarie applied for innocent-spouse relief for the liability, explaining that she was unaware of the tax liability and would suffer economic hardship if she was made to pay. The Commissioner of Internal Revenue (the Commissioner) (defendant) denied Valarie’s request for relief because it was untimely. Valarie petitioned the United States Tax Court for a redetermination.
Rule of Law
Issue
Holding and Reasoning (Vasquez, J.)
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