Steven and Jennie Jacobs - Page 4

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            112 Stat. 685, ___, respondent and Ms. Jacobs filed a stipulation                             
            of settled issues, agreeing that Ms. Jacobs "is entitled to                                   
            relief from liability under the innocent spouse provisions of                                 
            I.R.C. � 6015 for the 1992 taxable year."                                                     
                  On November 16, 1998, following the filing of respondent's                              
            opening brief, petitioner filed a motion to dismiss on the ground                             
            that his ailments were preventing him from preparing and filing a                             
            reply brief, and that "if the Court would see fit to grant a                                  
            dismissal it would be an act of mercy for which [petitioner]                                  
            would be eternally grateful".  The Court denied petitioner's                                  
            motion in an order explaining that under the Court's Rule 1231                                
            the granting of petitioner's motion would require entry of a                                  
            decision in favor of respondent.  The order informed the parties                              
            that the case was fully submitted and excused them from filing                                
            any additional briefs.                                                                        
                  Petitioner had an advertising business, creating story                                  
            boards for radio and TV advertisements and placing those                                      
            advertisements, and creating layouts for print brochures and                                  
            folios.  On Schedule C, petitioner reported gross income from the                             
            business of $21,876, which was allocated (rounded off) as                                     
            follows:                                                                                      


                  1 Unless otherwise stated, all Rule references are to the                               
            Tax Court Rules of Practice and Procedure, and all section                                    
            references are to the Internal Revenue Code in effect for the                                 
            taxable year in issue.                                                                        




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