- 2 - 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 SchoolPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011