Fredie Lynn Charlton - Page 1

          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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