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whether petitioner is entitled to relief from joint and several
income tax liability for 1996 pursuant to section 6015(b), (c),
or (f).
Background
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 he filed his
petition, petitioner resided in Los Angeles, California.2
Petitioner and Lesley Louise Becherer (Ms. Becherer) married
on February 23, 1994, and divorced on September 26, 1997.
Petitioner and Ms. Becherer filed a joint income tax return
for 1996. In the notice of deficiency for 1996, respondent
determined that petitioner and Ms. Becherer had five items of
unreported income. The five items consisted of income from four
employers and a distribution from the City of Clearwater. The
distribution from the City of Clearwater was attributable to
petitioner. The income received from one employer, Cenex
Services, was attributable to petitioner. The income received
from the remaining three employers, TTC Illinois, Trader
Publications, and Pennysaver, was attributable to Ms. Becherer.
Respondent determined a deficiency of $1,833 in petitioner’s and
Ms. Becherer’s 1996 Federal income tax liability. Apart from the
2 At trial, respondent orally moved that intervenor be
dismissed for lack of prosecution. That motion is denied by the
Court.
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