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liability under section 6015(b); (2) whether petitioner is liable
under section 6015(c)(4) to the extent she received disqualified
assets notwithstanding a valid election under section 6015(c);
and (3) whether respondent abused his discretion in denying
petitioner’s request for relief from joint and several liability
under section 6015(f).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
dollar amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition in this case was filed, petitioner resided in
Portland, Oregon.
Background
Petitioner and Mr. Ohrman were married in Seattle,
Washington, on March 26, 1988. On September 9, 1994, petitioner
and Mr. Ohrman purchased a personal residence on Birdshill Road
in Portland, Oregon (Birdshill residence). At the time of trial
in March 2003, petitioner was 53 years old and Mr. Ohrman was
56 years old.
Petitioner attended college for at least 2 years and worked
towards a teaching degree, but she did not graduate. From 1985
to 1995, petitioner worked as a lending officer at two large
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