T.C. Memo. 2001-76
UNITED STATES TAX COURT
FREDIE LYNN CHARLTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
SARAH K. HAWTHORNE, F.K.A. SARAH K. CHARLTON,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE,
Respondent*
Docket Nos. 11412-98, 11861-98. Filed March 27, 2001.
In Charlton v. Commissioner, 114 T.C. 333 (2000),
we held that (1) income from Medi-Task, a transcription
service, is self-employment income attributable to
Hawthorne (H), Charlton’s (C’s) former spouse;
(2) expenses related to rental cabins are not
deductible; and (3) C qualifies under sec. 6015(c),
I.R.C., for limitation of liability for tax resulting
from the Medi-Task income. We ordered C and respondent
(R) to compute C’s liability under sec. 6015(d),
I.R.C., as part of the Rule 155 computations. After we
filed our opinion in Charlton v. Commissioner, supra, R
determined that H is entitled to relief under section
6015(f). C disagrees with R’s determination.
* This Memorandum Opinion supplements Charlton v.
Commissioner, 114 T.C. 333 (2000).
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