Fredie Lynn Charlton - Page 3




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               1.   Whether unclaimed Medi-Task expenses totaling $2,050              
          are allocable to Hawthorne.  We hold that they are.                         
               2.   Whether the self-employment tax deduction resulting               
          from self-employment tax attributable to the unreported Medi-Task           
          income is allocable to Hawthorne.  We hold that it is.                      
               3.  Whether respondent’s determination that Hawthorne is               
          entitled to relief under section 6015(f) was an abuse of                    
          discretion.  We hold that it was not.                                       
                                     Background                                       
               Charlton and Hawthorne were married in 1989.  They filed a             
          joint tax return for 1994 on which they reported income from a              
          medical transcription business called Medi-Task and deducted                
          rental cabin expenses.                                                      
               Respondent determined a deficiency for 1994 based in part on           
          unreported Medi-Task income, self-employment tax related to Medi-           
          Task, a $2,050 deduction for Medi-Task expenses which Charlton              
          and Hawthorne had not deducted, and rental cabin expense                    
          deductions which respondent denied.                                         
               Charlton and Hawthorne were divorced in 1996.  Hawthorne               
          received Medi-Task, and Charlton received the rental cabins as a            
          part of their divorce settlement.                                           
               Charlton and Hawthorne filed petitions disputing                       
          respondent’s determination and alleging that they each qualified            
          for relief under section 6015.  We held that Medi-Task income was           
          self-employment income allocable to Hawthorne under sections 6017           





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