Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 2

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          After concessions,1 the sole issue for decision is whether                  
          petitioner wife is entitled to relief from joint and several                
          liability under section 6015(b)(1).2                                        
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years at issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.  References to petitioner in the singular are to                 
          Penelope J. Von Kalinowski.                                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time they filed              
          their petition with the Court, petitioners were residents of Los            
          Angeles, California.                                                        
               Petitioners jointly filed a Form 1040, U.S. Individual                 
          Income Tax Return, for each of the taxable years at issue.  With            
          respect to taxable year 1981, petitioners twice filed an amended            

               1  Without considering the application of the relief                   
          provisions of sec. 6015 to petitioner Penelope J. Von Kalinowski,           
          petitioners concede deficiencies of $179,230 and $81,495 for tax            
          years 1981 and 1982, respectively.  Respondent concedes the                 
          additions to tax under sec. 6653(a)(1) and (a)(2).                          
               2  Sec. 6015 was added by sec. 3201(a) of the Internal                 
          Revenue Service Restructuring and Reform Act of 1998, Pub. L.               
          105-206, 112 Stat. 734.  Sec. 6015 is effective with respect to             
          any tax liability arising after July 22, 1998, and any tax                  
          liability arising on or before July 22, 1998, that is unpaid on             
          that date.                                                                  

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