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The Petition and Proceedings to Date
By the petition, petitioner assigned error to respondent’s
determination of deficiencies, additions to tax, and penalties.3
She set forth as an affirmative defense her claim to relief from
joint and several liability under section 6015(c). Respondent
denied that he had erred and denied her claim under section
6015(c), and the case was set for trial at the Court’s trial
session commencing on December 4, 2000, in Houston, Texas.
The parties reached a tentative settlement just prior to
trial. When the case was called from the trial calendar, the
parties filed a stipulation of settled issues, pursuant to which
(1) respondent conceded the fraud penalty for all years and the
accuracy-related penalty for 1992 and 1993, (2) petitioner
conceded the accuracy-related penalty for 1991 and the additions
to tax for late filing for 1992 and 1993, and (3) each party
conceded portions of the business expense issues (subject, in
petitioner’s case, to her claim for section 6015(c) relief).
Petitioner also filed a motion for continuance at that time with
regard to the remaining business expense and section 6015(c)
issues, pending Mr. Fields’ payment of the deficiencies resulting
from his concession of such business expense issues in his
companion case.
3 At the time of the filing of the petition, petitioner
resided in Katy, Texas.
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