Irwin I. Skoller and Marsha Skoller - Page 3




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          in effect at the time the petition was filed.  The decision to be           
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           
               Respondent determined a deficiency of $5,804 in petitioners’           
          1994 Federal income tax and an accuracy-related penalty under               
          section 6662(a) of $1,161.  The issues are (1) whether                      
          petitioners may claim a business bad debt deduction under section           
          166; (2) whether petitioners are liable for the accuracy-related            
          penalty under section 6662(a); and (3) whether petitioner Marsha            
          Skoller (Ms. Skoller) is entitled to relief from joint and                  
          several liability under section 6015.2  Petitioners resided in              
          Freehold, New Jersey, at the time the petition was filed.                   
               Petitioners married on September 2, 1963, and separated in             
          May of 2000.  Petitioner Irwin I. Skoller (Mr. Skoller) is an               
          attorney with an LL.M. in taxation from New York University                 
          School of Law.  Ms. Skoller has a high school diploma.  Since               
          1983, Mr. Skoller has operated a tax consulting and accounting              
          business as a sole proprietor.  Ms. Skoller worked in Mr.                   
          Skoller’s office part time as an administrative assistant.  In              
          addition to providing general office assistance, her duties                 
          included reconciling the bank statements, making deposits, and              



               2  Respondent concedes that Ms. Skoller is eligible for                
          separate tax liability under sec. 6015(c).  This issue remained             
          for trial because Mr. Skoller objected.  See Corson v.                      
          Commissioner, 114 T.C. 354 (2000).                                          





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