Andrews Amankwah - Page 2




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          penalty under section 6662(a) in the amount of $1,079.1  After              
          concessions by the parties,2 the issue for decision is whether              
          petitioner is entitled to relief from joint and several liability           
          under section 6015.  We hold that he is not.                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  Petitioner resided in Phoenixville, Pennsylvania, at the            
          time that his petition was filed with the Court.                            
               Petitioner married Joyce Johnson Amankwah (now known as                
          Joyce Chester) in 1994.  Petitioner and Ms. Chester have a son,             
          who was born in 1995.                                                       
               Petitioner and Ms. Chester experienced financial                       
          difficulties during 1995 and 1996.  During 1995, Ms. Chester was            
          forced to take time away from her Schedule C business because of            
          complications resulting from her pregnancy.  Ms. Chester's                  
          Schedule C business was not profitable during 1995 (reporting a             

          1  All section references are to the Internal Revenue Code                  
          in effect for the taxable year in issue, and all Rule references            
          are to the Tax Court Rules of Practice and Procedure.                       
          2  Petitioner concedes that there was a failure to report a                 
          taxable pension and annuities distribution in the amount of                 
          $21,391 on the joint return that he filed for 1996 with Joyce               
          Johnson Amankwah.  Petitioner also concedes an adjustment in the            
          amount of $14 relating to an early withdrawal penalty.                      
          Respondent concedes an adjustment for interest income in the                
          amount of $20.  The parties agree that an adjustment in the                 
          amount of $347 for miscellaneous itemized deductions is purely a            
          mechanical matter.  Finally, petitioner does not contest that the           
          penalty under section 6662(a) is applicable.                                






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