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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 a
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