Estate of Keith L. Gurr - Page 3




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          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          
               Respondent determined deficiencies in petitioners' Federal             
          income taxes, additions to tax, and accuracy-related penalties as           
          follows:                                                                    

          Addition to Tax       Penalty                                               
          Year     Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)                    
          1992      $ 1,489            $  372            $  298                       
          1993       10,330             2,583             2,066                       

               At trial, the parties filed a written stipulation, wherein             
          petitioners conceded the above deficiencies, additions to tax,              
          and the accuracy-related penalties.3  The only issue for decision           
          is whether Delma P. Gurr (petitioner) is entitled to relief from            
          joint and several liability under section 6015 for the years at             
          issue.4  More specifically, petitioner seeks relief under section           
          6015(b), alternatively, limited liability relief under section              
          6015(c), and, in the further alternative, relief under section              


               3    After the case was heard and taken under advisement,              
          Keith L. Gurr died, and the Estate of Keith L. Gurr, Deceased,              
          Mary Julene Wooden, General Personal Representative, was                    
          substituted as petitioner.  Because of his health, Mr. Gurr did             
          not appear at trial or present any evidence.                                
               4    Sec. 6015 was enacted by sec. 3201(a) of the Internal             
          Revenue Service Restructuring and Reform Act of 1998, Pub. L.               
          105-206, 112 Stat. 734, and 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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