- 2 - reviewable by any other court, and this opinion should not be cited as authority. Respondent determined deficiencies in petitioner’s Federal income taxes and an addition to tax as follows: Addition to Tax Year Deficiency Sec. 6651(a)(1) 1993 $5,362 $1,171 1994 686 – After concessions, the issue for decision is whether petitioner is entitled to relief from joint and several liability pursuant to section 6015(c) for the 1993 deficiency and addition to tax. Background Vonnie W. Gillispie (petitioner) and Mike Gillispie (intervenor) were married during the years in issue and divorced on June 16, 1996. During the years in issue, intervenor was the sole proprietor of a residential and commercial painting business known as “Mike’s Painting”. Intervenor maintained an individual business checking account for Mike’s Painting. Petitioner and intervenor maintained separate checking accounts in 1993. Petitioner and intervenor filed joint Federal income tax returns for 1993 and 1994. The 1993 return was prepared by Jo Abney (Ms. Abney), intervenor’s aunt, and was filed on January 8, 1997. A Schedule C, Profit or Loss From Business, for Mike’s Painting was attached to the return. The Schedule C reported gross income of $188,632 and expenses of $186,473, resulting in business income of $2,159.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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