114 T.C. No. 24
UNITED STATES TAX COURT
THOMAS CORSON AND JUDITH CORSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27181-85. Filed May 18, 2000.
Ps T and J filed a joint Federal income tax return
for the taxable year 1981, and R issued a notice of
deficiency for taxes, additions to tax, and interest
related thereto. Ps filed a joint petition for
redetermination with this Court, and J later amended
the petition to assert a claim for innocent spouse
relief. Subsequently, J and R entered into a
stipulation in which J conceded liability for the
deficiencies determined by R but preserved her right to
pursue innocent spouse relief. T and R then signed a
similar stipulation settling all issues pertaining to
T’s tax liabilities for the 1981 year. At a later
date, J and R also executed a stipulated settlement
granting J complete relief from joint and several
liability pursuant to sec. 6015(c), I.R.C. When T
thereafter refused to sign a stipulated decision based
on these agreements, R filed a motion for entry of
decision. T contends that provisions of the Internal
Revenue Service Restructuring and Reform Act of 1998,
Pub. L. 105-206, sec. 3201, 112 Stat. 685, 734, confer
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