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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioner’s Federal
income taxes of $4,092 and $6,972, and accuracy-related penalties
of $818.40 and $1,394.40, for the taxable years 1997 and 1998.
The issue for decision is whether petitioner is entitled to
full or partial relief from joint and several liability under
section 6015 for the deficiencies and penalties determined by
respondent.1
Background
Some of the facts have been stipulated and are so found.
The stipulations of fact and those attached exhibits which were
admitted into evidence are incorporated herein by this reference.
Petitioner resided in Buffalo Grove, Illinois, on the date the
petition was filed in this case.
Petitioner has a high school education. Over the years she
has worked in a variety of areas, including retail sales,
bartending, and secretarial work. During the years in issue, she
was employed on a part-time basis by several employers, including
a bed and breakfast, an eye doctor, and a law office. Petitioner
earned approximately $6,000 in 1997 and approximately $10,000 in
1Petitioner does not challenge respondent’s determinations
in the notice of deficiency concerning the underlying
deficiencies.
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