- 2 -
liabilities for 1983, 1984, 1985, and 1986.2 Respondent
determined that petitioner was not entitled to any relief under
section 6015, and we decide whether to sustain that
determination. We hold we shall.
FINDINGS OF FACT
Some facts were stipulated and are so found. The
stipulations of fact and the accompanying exhibits are
incorporated herein by this reference. Petitioner resided in San
Marino, California, when her petition to this Court was filed.
Petitioner is a college educated woman who as a licensed
realtor earned $18,000 in real estate commissions in 2002. At
the time of trial, she and her husband, John E. Albin (Albin),
were living on Social Security, rental income, and income that
she earned working 14 hours per week at a retail outlet. She and
Albin (collectively, the Albins) have been happily married and
living together at all relevant times, and during that time he
was neither evasive nor deceitful to her as to their finances.
The Albins filed joint 1983, 1984, 1985, and 1986 Forms
1040, U.S. Individual Income Tax Return, that were prepared by
Albin’s accountant in consultation with Albin. Petitioner was
not involved in the preparation of these returns. Albin, outside
the accountant’s presence, presented each of these returns to
2 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011