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portion of the distribution. The 1995 and the 1996 returns were
prepared by an accountant.
Petitioner and Ms. Chester were separated in February 1998.
By notice of deficiency dated January 6, 1999, respondent
determined that on their joint return for 1996, petitioner and
Ms. Chester failed to report taxable distributions from Ms.
Chester's retirement account in the amount of $21,391.
Petitioner filed a petition in this Court requesting relief
from joint and several liability under section 6015.
ULTIMATE FINDINGS OF FACT
Petitioner had actual knowledge of all distributions from
Ms. Chester's retirement account during the year in issue.
Further, petitioner had actual knowledge at the time that he
filed the 1996 joint return of the failure to report the taxable
distributions totaling $21,391 from Ms. Chester's retirement
account.
OPINION
We begin with section 6015. Section 6015 provides relief
from joint and several liability to any taxpayer who meets the
requirements of subsection (b). The requirements of section
6015(b) that must be met are as follows:
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