Amanda Renee Stewart, Petitioner, and Ahmed Zeid, Intervenor, T. C. Sum. Op. 2025-3, filed 3/11/25, carried the “separate checks” principle to the max and beyond.

STJ Jennifer E. (“Publius”) Siegel tells all: “Petitioner and intervenor kept their finances largely separate throughout their marriage. For example, they would split joint household expenses by individually putting money for the specific item(s) into a shared account maintained for that purpose. If they gave a gift as a couple, they would each pay for half. The two tracked their expenses through a smartphone application and would periodically reconcile them, settling up when they did so. Petitioner frequently fronted the money for joint expenses and was later reimbursed by intervenor. The two did not own any property or investments together.” T. C. Sum. Op. 2025-3, at p. 2. And they each separately entered their information on the tax prep software for their 1040 MFJ for year at issue.

So when the parties divorce and IRS hits them with a SND, Ahmed claims it’s unfair to let Amanda Renee off the hook, and she should help him amend their return to let him pick up the unreported income and add some deductions from his business, in which she took no part.

STJ Publius isn’t interested.

“As an initial matter, the Court has no authority to require parties to amend their income tax returns. Further, we agree with the IRS’s concession that petitioner should be relieved from joint and several liability under section 6015(c) for the portion of the deficiency and penalty caused by intervenor’s unreported income from his business.” T. C. 2025-3, at p. 4.

Ahmed wants to relitigate the deficiency, but he never petitioned the SND. And innocent spouse cases are restricted to eligibility for relief. Amanda Renee checks all the boxes for Section 6015(c) apportioned. All Ahmed has is the Michael Corleone gambit, “don’t ask me about my business” variation.