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petitioners’ Federal income taxes for the years 1996 and 1997,
respectively, and a penalty under section 6662(a) of $1,910 for
the year 1996.
The petitioners have conceded the deficiencies and penalty
by stipulation. The only issue we must decide is whether either
petitioner is entitled to relief from joint and several liability
under section 6015.
Some of the facts in this case have been stipulated and are
so found. Petitioners resided in Burbank, California, at the
time they filed their petition.
During each of the taxable years at issue, petitioner Gary
L. Pendleton (Gary) maintained a sole proprietorship electrician
business which was operated out of the personal residence of
petitioners. In addition, Gary worked as an electrician for a
number of employers. Most of his work was commercial work. Gary
did his electrical work in the field.
During each of the taxable years at issue, petitioner Jolene
K. Pendleton (Jolene) worked as a staffing/placement specialist
for Royal Associates. Jolene earned $52,226 of the $87,773
reported as W-2 wages for 1996 and $52,025 of the $85,270
reported as W-2 wages for 1997.
Petitioners were married in June 1990. They were separated
in January 1997. However, during 1997, Gary “still was living”
with Jolene. He would go to her home every night and spend the
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