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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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