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pursuant to section 6015(b), (c), or (f).1 Petitioner does not
otherwise contest respondent’s deficiency determination.
FINDINGS OF FACT
Petitioner and Ronald Tice were married from 1994 to 1998.
Petitioner was responsible for the household finances. During
their marriage, Mr. Tice was verbally abusive towards petitioner,
and on several occasions, including one in 1997, petitioner
obtained a protective order against Mr. Tice.
During 1997, petitioner was a medical assistant for Dr.
William Fleming, and Mr. Tice performed services for Prestige
Home Centers, Inc. (Prestige), Kelly Services, Inc. (Kelly), and
T.D.I., Inc. (TDI).
In 1996, Mr. Tice began driving rental trucks from Florida
to other States (e.g., New York and Michigan) for TDI and
informed petitioner of his pay rate of 19 cents per mile. Mr.
Tice was away from home 3 weeks each month he worked for TDI and
would inform petitioner of his whereabouts en route or when he
arrived at his destination. Petitioner was aware of the
approximate amount of Mr. Tice’s weekly income from TDI.
Petitioner believed Mr. Tice’s truck driving required him to
spend too much time away from home. In response, Mr. Tice
promised that he would stop working for TDI. Despite Mr. Tice’s
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
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Last modified: May 25, 2011