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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.
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