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112 Stat. 685, ___, respondent and Ms. Jacobs filed a stipulation
of settled issues, agreeing that Ms. Jacobs "is entitled to
relief from liability under the innocent spouse provisions of
I.R.C. � 6015 for the 1992 taxable year."
On November 16, 1998, following the filing of respondent's
opening brief, petitioner filed a motion to dismiss on the ground
that his ailments were preventing him from preparing and filing a
reply brief, and that "if the Court would see fit to grant a
dismissal it would be an act of mercy for which [petitioner]
would be eternally grateful". The Court denied petitioner's
motion in an order explaining that under the Court's Rule 1231
the granting of petitioner's motion would require entry of a
decision in favor of respondent. The order informed the parties
that the case was fully submitted and excused them from filing
any additional briefs.
Petitioner had an advertising business, creating story
boards for radio and TV advertisements and placing those
advertisements, and creating layouts for print brochures and
folios. On Schedule C, petitioner reported gross income from the
business of $21,876, which was allocated (rounded off) as
follows:
1 Unless otherwise stated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
taxable year in issue.
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Last modified: May 25, 2011