Joanne Salvi Vanover is a human resources specialist with a masters’ degree.  She is able to claim Section 6015(c) apportioned innocent spousery, but only to the extent IRS allowed relief at Exam. As to those items, Joanne did not have actual (as opposed to constructive) knowledge. The greater standard for apportionment saves part of the day.

The problem, as usual, is the stipulations. Joanne, pro se, is up against IRS’ two lawyers and her ex’s lawyer plus student. A review of Judge Courtney D. (“CD”) Jones’ opinion shows numerous instances where Joanne tries to contradict her stipulations, without success.

While Judge CD Jones is sympathetic to Joanne’s claims of abuse, and takes them seriously, her criminal conviction for domestic violence and disorderly conduct doesn’t help. T. C. Memo. 2025-37, at p. 7. Her ex’s testimony is credible.

Ultimately, it hurts to be educated. “Ms. Salvi is highly educated, with both a bachelor’s and a master’s degree. Ms. Salvi is currently employed as a human resource professional and owns her home. These facts do not support a finding that it would be inequitable to impose joint and several liability based on Ms. Salvi’s economic position.” T. C. Memo. 2025-37, at p. 27.

The case is Joanne Salvi Vanover, Petitioner, and Michael D. Vanover, Intervenor, T. C. Memo. 2025-37, filed 4/22/25.