Kathy A. King - Page 3




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               The sole issue for decision is whether petitioner is                   
          entitled to relief from joint liability under section 6015.  The            
          underlying deficiency determined by respondent in the notice of             
          deficiency is not at issue.  Curtis T. Freeman (intervenor) is              
          the former spouse of petitioner and filed an intervention in this           
          proceeding pursuant to section 6015(e)(4) objecting to the                  
          granting of relief to petitioner under section 6015.  See Interim           
          Rule 325; King v. Commissioner, 115 T.C. 118 (2000).                        
               At the time the petition was filed, and at the time the                
          notice of intervention was filed, the legal residence of                    
          petitioner and intervenor was Hartsville, South Carolina.                   
               Petitioner and intervenor were married during 1982.  During            
          1981, intervenor had purchased approximately 100 acres of land at           
          Hartsville, South Carolina, and had begun a cattle-raising                  
          activity that continued for several years, including the 1993 tax           
          year at issue.  This activity commenced with one or two cows,               
          then grew to a herd of 25-30 cows with intermittent sales and               
          purchases of cows and calves along the way.  It was by no means a           
          profitable activity, although intervenor had the expectation                
          that, over time, the activity would become profitable.                      
          Intervenor allowed some of his neighbors to pasture their                   
          livestock on the property, and the neighbors, in turn, assisted             
          to some degree in caring for intervenor’s livestock when                    
          intervenor was frequently away from home in connection with his             





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