Case: Taxpayer Participated in Prior Case, Innocent Spouse Relief Denied Due to Res Judicata (T.C. Memo) (IRC §6015)

Taxpayer’s claim for innocent spouse relief was barred by res judicata, affirming the IRS’s denial of relief. Taxpayer, a married individual, sought innocent spouse relief for tax years 2006 through 2010 and 2014 after a prior Tax Court case had determined deficiencies and penalties for those years. The court held that taxpayer meaningfully participated in the prior proceeding because: 1) she was jointly represented by counsel throughout the case; 2) she personally signed the stipulated decision document; 3) she was kept informed of the case’s progression; and (4) she had the opportunity to raise the innocent spouse issue during the ...