- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011