Fredie Lynn Charlton - Page 3

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          Medi-Task is allocated to petitioner Sarah K. Hawthorne                     
          (Hawthorne) for purposes of computing self-employment tax for               
          1994.  We hold that it is.                                                  
               2.   Whether petitioners may deduct expenses relating to               
          their rental cabins in 1994.  We hold that they may not.                    
               3.   Whether petitioner Fredie Lynn Charlton (Charlton) is             
          entitled to relief from joint and several liability under section           
          6015(b) for the income tax deficiency arising from petitioners’             
          1994 joint return.  We hold that he is not.                                 
               4.   Whether petitioner Fredie Lynn Charlton qualifies for             
          limitation of liability under section 6015(c) for the income tax            
          deficiency arising from petitioners’ 1994 joint return.  We hold            
          that he does to the extent described below.                                 
               5.   Whether we have jurisdiction to review whether relief             
          is available to petitioner Sarah K. Hawthorne under section                 
          6015(f).  We hold that we do.  Thus, we will delay entry of                 
          decision to permit Hawthorne and respondent to report on the                
          status of Hawthorne’s application for relief under section                  
          6015(f), and if relief is denied, to file a motion as part of               
          this docketed case requesting our review of the Secretary’s                 
          denial.                                                                     
               Section references are to the Internal Revenue Code in                 
          effect for 1994.  Rule references are to the Tax Court Rules of             
          Practice and Procedure.                                                     






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