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, conferPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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