Michael G. Culver and Christine M. Culver - Page 2




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               Orrin L. Grover, for petitioner Michael G. Culver.                     
               Christine M. Culver, pro se.                                           
               Nhi T. Luu-Sanders, for respondent.                                    


               SWIFT, Judge:  Respondent determined deficiencies in                   
          petitioners' 1994 and 1995 Federal income taxes and accuracy-               
          related penalties as follows:                                               

                                                  Accuracy-Related                    
                                                  Penalty                             
                     Year        Deficiency       Sec. 6662(a)                        
                    1994      $12,572                  $2,514                         
                    1995      18,339                   3,668                          

               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After settlement of some issues, the only issue for decision           
          is whether petitioner Michael G. Culver (Michael) qualifies for             
          relief from liability under section 6015(b) or (c).                         

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petition was filed, Michael resided in                 
          Woodburn, Oregon, and petitioner Christine M. Culver (Christine)            
          was incarcerated in an Oregon State penitentiary.                           






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