- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011