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SLEETH v. C.I.R.

No. 20-10221.

991 F.3d 1201 (2021)

Lori D. SLEETH, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

March 19, 2021.

Attorney(s) appearing for the Case

Madeleine DeMeules , Legal Services Center of Harvard Law School, Keith Fogg , Harvard Law School, Federal Tax Clinic at Legal Services Center, Jamaica Plain, MA, Carlton M. Smith, Carlton M. Smith, Esq. , New York, NY, for Petitioner-Appellant.

Sherra Tinyi Wong , Thomas J. Clark , U.S. Department of Justice, Chief Appellate Section Tax Division, Michael J. Desmond , Chief Counsel — IRS, Washington, DC, for Respondent-Appellee.

Before GRANT, TJOFLAT, and ED CARNES, Circuit Judges.

Lori and David Sleeth filed joint tax returns for the 2008, 2009, and 2010 tax years—but never paid the corresponding tax liabilities. Lori asked the tax court to sever her liability for those unpaid taxes because she was an "innocent spouse." The tax court denied her request, and she now asks that we reverse. But because...

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