Henry v. Comm’r, T.C. Memo. 201924, 2019 WL 1385242 (2019)
(a) Facts: Husband and wife married in 1997 and divorced in 2013. While the divorce case was pending, the parties filed a joint income tax return for tax year 2012. The return did not report $14,650 in income earned by the husband from his second job as a church musician.
The IRS assessed a deficiency, which neither party contested. The IRS then seized funds from the wife’s 2014 tax return to satisfy the deficiency. The wife moved for innocent spouse relief. The IRS granted relief but denied the wife a refund. The wife sought review in the Tax Court.