- 2 - petitioners’ 1995 Federal income taxes. Respondent also determined that neither petitioner qualified for relief from joint and several liability pursuant to section 6015(b), (c), or (f). After concessions,2 the issue for decision is each petitioner’s entitlement to relief from joint and several liability pursuant to section 6015(b) and (c) for 1995.3 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time they filed the petitions, petitioners both resided in Westlake Village, California. Sometime before 1990, petitioners married. Petitioners filed joint income tax returns every year they were married. During the last half of 1994 and all of 1995, petitioners lived apart. 1(...continued) the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2 Petitioners concede the adjustments determined in the notice of deficiency. Respondent and petitioners have made concessions regarding petitioners’ entitlement to relief pursuant to sec. 6015(b) and (c). For purposes of clarity, those concessions are discussed infra. 3 In their petitions, petitioners sought relief pursuant to sec. 6015(b) and (c). Accordingly, sec. 6015(f) is not in issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011