Fredie Lynn Charlton - Page 1
















                                 T.C. Memo. 2001-76                                   


                               UNITED STATES TAX COURT                                


                         FREDIE LYNN CHARLTON, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                    SARAH K. HAWTHORNE, F.K.A. SARAH K. CHARLTON,                     
                   Petitioner v. COMMISSIONER OF INTERNAL REVENUE,                    
                                     Respondent*                                      


               Docket Nos. 11412-98, 11861-98.    Filed March 27, 2001.               

               In Charlton v. Commissioner, 114 T.C. 333 (2000),                      
               we held that (1) income from Medi-Task, a transcription                
               service, is self-employment income attributable to                     
               Hawthorne (H), Charlton’s (C’s) former spouse;                         
               (2) expenses related to rental cabins are not                          
               deductible; and (3) C qualifies under sec. 6015(c),                    
               I.R.C., for limitation of liability for tax resulting                  
               from the Medi-Task income.  We ordered C and respondent                
               (R) to compute C’s liability under sec. 6015(d),                       
               I.R.C., as part of the Rule 155 computations.  After we                
               filed our opinion in Charlton v. Commissioner, supra, R                
               determined that H is entitled to relief under section                  
               6015(f).  C disagrees with R’s determination.                          


               *  This Memorandum Opinion supplements Charlton v.                     
          Commissioner, 114 T.C. 333 (2000).                                          




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