- 3 - 6015(f). Respondent and Keith L. Gurr (Mr. Gurr) opposed petitioner's claim. However, in a posttrial reply brief, respondent conceded petitioner's entitlement to limited liability relief under section 6015(c) to the extent of 50 percent of the deficiencies attributable to three adjustments in the notice of deficiency for 1992 and four notice of deficiency adjustments for the year 1993 relating to certain real estate transactions. Respondent made no concession with respect to one adjustment in the 1993 notice of deficiency relating to the taxable portion of Social Security benefits received by petitioners that year. Given the concession of respondent, petitioner, nevertheless, maintains her entitlement to total relief under section 6015(b), (c), and (f). Some of the facts were stipulated. Those facts, and the annexed exhibits, are so found and are incorporated herein by reference. At the time the petition was filed, Mr. Gurr's legal residence was Sandy, Utah, and petitioner's legal residence was West Jordan, Utah. Petitioner and Mr. Gurr were married in 1952. Their marriage lasted 43 years. They separated on November 4, 1993, and were divorced on August 29, 1995. They had five children. Petitioner had one other child from a prior marriage. Respondent issued separate notices of deficiency to petitioner and Mr. Gurr, and a joint petition was filed timely.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011