Pamela Renee Wiggins - Page 3

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          income tax liability.  That liability is based in part on an                
          unpaid liability reported on a timely filed joint 1992 Federal              
          income tax return, and in part upon a deficiency determined and             
          assessed several years later.  Petitioner’s request was denied in           
          a notice of final determination issued by respondent on February            
          21, 2001.  She timely petitioned this Court for review of                   
          respondent’s determination.  See sec. 6015(e).                              
               The issue for decision is whether respondent’s refusal to              
          relieve petitioner from liability under section 6015 with respect           
          to a 1992 Federal income tax liability is an abuse of discretion.           
          We hold that it was not, but for a reason other than that                   
          advanced by respondent.                                                     
          Background                                                                  
               Some of the facts have been stipulated and are so found.  At           
          the time the petition was filed, petitioner resided in Roanoke,             
          Virginia.                                                                   
               Petitioner and Peter Stimeling (Mr. Stimeling) were married            
          to each other on June 9, 1990.  They separated in February 1993             
          and were divorced on October 25, 1994.  During 1992, petitioner             
          and Mr. Stimeling worked together as employees of Valley View               
          Associates, Ltd.  Each received a Form W-2, Wage and Tax                    
          Statement, for that year on which the following information is              
          reported:                                                                   








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