Betsy O. Muhn - Page 2

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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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