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related penalty under section 6662(a)1 of $2,072 for the taxable
year 1995.
After concessions,2 the only issue for decision3 is whether
David R. Braden is entitled to relief from liability under
section 6015(b)(1) for the income tax deficiency determined by
respondent with respect to petitioners’ jointly filed Federal
income tax return for 1995. References to petitioner refer to
David R. Braden, and references to Ms. Braden refer to Sharon F.
Braden.4
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
2Petitioner Sharon F. Braden and respondent filed a
stipulation of settled issues in which Ms. Braden conceded she is
liable for a deficiency in income tax for taxable year 1995 in
the amount of $16,525, and respondent conceded that Ms. Braden is
not liable for the accuracy-related penalty under sec. 6662(a)
for 1995. Respondent also conceded the sec. 6662(a) penalty with
respect to petitioner David R. Braden.
3The only other issues raised in the notice of deficiency
are computational.
4Following petitioners’ divorce, Ms. Braden changed her name
to Sharon Mueller. Since Ms. Braden has not moved to change the
caption in this case to reflect her new surname, however, we
refer to her in this opinion as Ms. Braden.
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