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).Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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