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Addition to Tax/Penalty
Year Deficiency Sec. 6651(a) Sec. 6662(a)
1992 $7,589 -- $1,096
1993 90,049 $21,647 17,554
1994 202,878 -- 40,507
Respondent also determined that petitioner is not entitled to
relief from joint and several liability for 1989, 1990, and 1991.
The petition seeks relief from both determinations. The issue
for decision is whether petitioner is eligible for relief under
section 6015 for any of the years 1989 through 1994.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Texas at the time she filed the petition in
this case.
Petitioner was born and raised in Medellin, Colombia. In
1976, petitioner graduated from Asbury College in Wilmore,
Kentucky, and, in 1981, she graduated with a degree of Master of
Science in Education from Baylor University in Texas. Thereafter
she was employed as an elementary school teacher, and she
received wages as a teacher during each of the years in issue.
In 1992, petitioner graduated from the Reynaldo G. Garza School
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