Vonnie W. Gillispie - Page 3




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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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