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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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