Alva Cotter Shell IV, Petitioner, and Jamie L. Jones, Intervenor - Page 3

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          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           
               Pursuant to the provisions of section 6015, petitioner made            
          an administrative request for relief from a 1996 Federal income             
          tax deficiency.  Respondent denied petitioner’s request for                 
          relief in a final notice of determination issued on July 11,                
          2002.  Petitioner timely filed a petition with this Court under             
          section 6015(e) for review of respondent’s determination.                   
          Intervenor, petitioner’s former wife, filed a Notice of                     
          Intervention under Rule 325(b) and opposes such relief.                     
               The sole issue for decision is whether respondent abused his           
          discretion in denying petitioner relief from joint and several              
          liability under section 6015(f).  We hold that he did not.                  
          Background                                                                  
               Some of the facts have been stipulated, and are so found.              
          Petitioner resided in Pitts, Georgia, at the time that his                  
          petition was filed with the Court.                                          
               Petitioner and intervenor Jamie L. Jones (intervenor) were             
          married to each other on May 19, 1990, and had one child, a son,            
          during their marriage.                                                      
               During 1996, petitioner worked as a full-time employee for             
          the City of Cordele and as a part-time employee for Gin Co., Inc.           
          Petitioner earned income of $13,855 and $3,206, respectively, at            
          each job in 1996.                                                           






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