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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After a concession by petitioner, this Court must decide
whether petitioner is entitled to relief from liability under
section 6015 with respect to the income tax deficiency and the
section 6662(a) accuracy-related penalty.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Forest Grove, Oregon, at the
time he filed his petition.
Petitioner and intervenor Elena Parker (Mrs. Parker) were
married on January 5, 1991. During their marriage, petitioner
and Mrs. Parker had two children. In the early years of the
marriage, petitioner earned a living as a church organist and
choir director, a piano teacher, a composer, and a master
locksmith on antique clocks.
In 1994, petitioner was treated for depression and panic
disorder by Dr. Alan Morgenstern (Dr. Morgenstern), a
psychiatrist. Dr. Morgenstern referred petitioner to the
Harborview Medical Center (Harborview) in Seattle, Washington. At
Harborview, petitioner was evaluated by Dr. Deborah S. Cowley
(Dr. Cowley). Dr. Cowley confirmed petitioner’s depression and
panic disorder and recommended treatment.
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Last modified: May 25, 2011