Ruthe G. Ohrman - Page 2

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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.                                                           
               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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