T.C. Memo. 2001-318
UNITED STATES TAX COURT
TONY D. ISHIZAKI, Petitioner, AND
RANG SUN PARK ISHIZAKI, Intervenor v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11358-99. Filed December 27, 2001.
P and I filed a joint 1995 Federal income tax
return. Following examination, R determined that
constructive dividend income from a furniture business
operated by the spouses had been omitted on the 1995
return. After a joint notice of deficiency was issued
to P and I, P filed a petition with this Court not
challenging R’s determinations but seeking relief from
joint and several liability. I subsequently intervened
in the proceeding, disputing P’s entitlement to the
relief sought.
Held: P has failed to establish his entitlement
to relief from joint and several liability pursuant to
either subsec. (b) or subsec. (c) of sec. 6015, I.R.C.
Joseph E. Diamond, for petitioner.
Mufthiha Sabaratnam, for intervenor.
David R. Jojola, for respondent.
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