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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.
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