114 T.C. No. 22
UNITED STATES TAX COURT
FREDIE LYNN CHARLTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
SARAH K. HAWTHORNE, f.k.a. SARAH K. CHARLTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 11412-98, 11861-98. Filed May 16, 2000.
Ps were married in 1989, separated in 1995, and
divorced in 1996. In 1994, W operated Medi-Task, a
physician’s transcription business. H was employed
full time by a large corporation until September 1994.
In the fall of 1994, he moved to a lake and began to
renovate some rental cabins. Ps filed a joint tax
return for 1994 in which they reported that they had
self-employment tax liability for the transcription
business and deducted rental cabin expenses.
R determined a deficiency based in part on
adjustments to Ps’ self-employment tax and denial of
deductions relating to the cabins. Ps filed petitions
disputing R’s determination. Ps also alleged they each
qualified for relief as an innocent spouse.
H contends that he qualifies for relief under sec.
6015(b) and (c), I.R.C. W contended at trial that she
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