Belma Begic, Petitioner and Zamir Jahic, Intervenor, Petitioners
T.C.
Opinion
RECOFDE D SERVIC E -P'- JUDG E T .C . Memo . 2007-12 6 UNITED STATES TAX COURT BELMA BEGIC, Petitioner, AND ZAMIR JAHIC, Intervenor V . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 11847-05 . Filed May 21, 2007 .
Harry Charles , for petitioner .
Zamir Jahic, pro se .
Steven W . LaBounty , for respondent .
MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge : The issue for decision is whether petitione r is entitled to innocent spouse relief pursuant to section 6015 . 1
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SERVE D MAY 21 2007
FINDINGS OF FAC T
On May 31, 1996, petitioner and intervenor were married in Norway . From January 2001 until August 2002, petitioner attended college in Norway, where she studied electrical engineering .
From September 2002 until September 2003, petitioner lived and worked in California . During 2001 and 2002, Mr . Jahic owned and operated a coffee shop and a night club in Missouri . In addition, he maintained the books and records relating to the businesses . Petitioner did not participate in, and was not familiar with, the day-to-day operations of the businesses .
Petitioner and Mr . Jahic filed joint Federal income tax returns relating to 2001 and 2002 . Mr . Jahic prepared and signed the returns on behalf of petitioner, but he did not show the returns to, or discuss the items of income with, petitioner . On May 8, 2004, petitioner and Mr . Jahic's marriage was dissolved .
On December 24, 2004, petitioner timely sent respondent a Form 8857, Request for Innocent Spouse Relief, relating to 2001 and 2002 . On March 22, 2005, respondent sent petitioner and Mr .
Jahic a notice of deficiency relating to 2001 and 2002 .
Respondent determined deficiencies and section 6662(a) accuracy- related penalties relating to 2001 and 2002 . On June 27, 2005 , 1 ( .
. . continued ) the Internal Revenue Code in effect for the years in issue .
petitioner, while residing in St . Louis, Missouri, filed her petition with the Court . On October 31, 2005, Mr . Jahic filed his notice of intervention with the Court .
OPINION
Petitioner did not know about the items giving rise to the deficiency, participate in the daily operations of the businesses, or sign the tax return . Accordingly, she is entitled to relief pursuant to section 6015(c) .
Contentions we have not addressed are irrelevant, moot, or meritless .
To reflect the foregoing, Decision will be entere d for petitioner .
- Unless otherwise indicated, all section references are to (continued .