Except it usually is in an innocent spouse Section 6015(f) equity case. Jessica Lynn Grady, a/k/a Jessica Lynn Gans, 2021 T. C. Sum. Op. 29, filed 8/17/21* surely knew her deadbeat ex would never cough up for the five (count ’em, five) years at issue. He specialized in nonfiling and busted IAs. And the IRS’ CCISO, the Cincinnati Bengals, chewed up Jessica’s application. Her timely submitted Form 12509, Statement of Disagreement requesting a hearing with the IRS Office of Appeals (Appeals Office) met no better fate.

“After its review the Appeals Office agreed with the preliminary determination to deny Ms. Gans’ request for innocent spouse relief and issued a final determination letter…stating: ‘Our review of the facts and circumstances of your claim didn’t show it would be unfair to hold you jointly responsible. You didn’t have a reasonable expectation that the person you filed the joint return with would or could pay the tax.’ 2021 T. C. Sum. Op. 29, at p. 11.

But the Bengals and Appeals didn’t reckon with two savvy ladies, Cynthia S. Agostini, EA, USTCP, whose website boasts that she holds a “a distinction held by fewer than 100 tax professionals nationwide,” and STJ Diana L (“The Taxpayer’s Friend”) Leyden.

Cindy and STJ Di review Jessica’s sad tale of ignorance, oppression, poverty, disease, miscarriages, substance abusing son, deadbeat ex, and retiring new spouse, and give Jessica the full boat, leaving IRS with guilty knowledge and nothing else, as Jessica grabs every brass ring for streamliner for one year, and scores equity everywhere else.

Happy ending.

*Jessica Lynn Grady 2021 T. C. Sum. Op. 29