- 2 - The sole issue for decision is whether petitioner is entitled to innocent spouse relief pursuant to section 6013(e). Petitioner concedes that respondent's determinations in the notice of deficiency are otherwise correct. Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. All dollar figures are rounded. General Findings This case was submitted with fully stipulated facts under Rule 122. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time the petition was filed, petitioner resided in Ruidoso, New Mexico. She has been married to her husband, John N. Muhn, for approximately 42 years. Background Petitioner attended the University of Texas at El Paso and Southern Methodist University for 2 years. She did not take any accounting or business classes while attending college. Mr. Muhn had been an accountant for Atlantic Richfield Corp. before retiring on November 1, 1984. He took care of all of the family's financial matters. During 1991, petitioner was employed by Home Health Services and briefly by American Greetings; Mr. Muhn was employed as aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011