Thomas Corson and Judith Corson - Page 1

                                   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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