Gary L. and Jolene K. Pendleton - Page 3

                                        - 2 -                                         
          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             

Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011