- 2 - income tax liability. That liability is based in part on an unpaid liability reported on a timely filed joint 1992 Federal income tax return, and in part upon a deficiency determined and assessed several years later. Petitioner’s request was denied in a notice of final determination issued by respondent on February 21, 2001. She timely petitioned this Court for review of respondent’s determination. See sec. 6015(e). The issue for decision is whether respondent’s refusal to relieve petitioner from liability under section 6015 with respect to a 1992 Federal income tax liability is an abuse of discretion. We hold that it was not, but for a reason other than that advanced by respondent. Background Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioner resided in Roanoke, Virginia. Petitioner and Peter Stimeling (Mr. Stimeling) were married to each other on June 9, 1990. They separated in February 1993 and were divorced on October 25, 1994. During 1992, petitioner and Mr. Stimeling worked together as employees of Valley View Associates, Ltd. Each received a Form W-2, Wage and Tax Statement, for that year on which the following information is reported:Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011