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subsequent section references are to the Internal Revenue Code in
effect for the year in issue.
Respondent determined a deficiency in petitioner’s Federal
income tax of $7,746, and an accuracy-related penalty of $1,549,
for the taxable year 1998. The sole issue for decision is
whether petitioner is entitled to relief from joint and several
liability for the deficiency and penalty pursuant to section
6015.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Wilson County, North Carolina, on the date the petition was filed
in this case.
Petitioner is a college graduate and is an executive vice
president of Reliant Management Group, a management fund that
works with criminal justice programs. During the year in issue,
petitioner’s primary employment was initially at the North
Carolina Department of Corrections as the head of probation and
parole in Wake County, and later at a management firm called
Civigenics, Inc. He received from these employers taxable wages
of $14,898 and $35,613, respectively. Federal income taxes were
withheld by both of these employers. In addition, petitioner
received compensation from various other sources totaling
$10,048.
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