-2-
Held: deductions related to Medi-Task are
allocable to H. See sec. 6015(d)(3), I.R.C.
Held, further, R’s determination that H was
entitled to relief under sec. 6015(f), I.R.C., was not
an abuse of discretion.
Fredie Lynn Charlton, pro se.
Sarah K. Hawthorne, pro se.
Carl D. Inskeep, Sheila R. Pattison, Deborah H. Delgado, and
Lewis J. Hubbard, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
COLVIN, Judge: This matter is before us to resolve a
dispute arising in the Rule 1551 computations submitted by
petitioner Fredie Lynn Charlton (Charlton) and respondent.
Charlton sought relief under section 6015.2
Following concessions,3 we must decide the following issues:
1 Rule references are to the Tax Court Rules of Practice
and Procedure. Section references are to the Internal Revenue
Code in effect during 1994, except section 6015, which was
enacted in 1998.
2 Docket No. 11861-98, the case of Sarah K. Hawthorne,
formerly known as Sarah K. Charlton and now known as Sarah K.
Mayor, was consolidated with this case for trial, briefing, and
opinion.
3 The parties agree that the total deficiency is $15,192.
They dispute whether $8,320 of that amount should be allocable to
Charlton, Hawthorne, or jointly to both of them under sec.
6015(d).
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