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liability under section 6015(b);1 (2) whether petitioner is
eligible for relief from joint and several liability under
section 6015(c); and (3) whether respondent abused his discretion
in denying petitioner’s request for relief from joint and several
liability under section 6015(f).
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts and accompanying exhibits are, by this reference,
incorporated in our findings. At the time the petition in this
case was filed, petitioner resided in Navarre, Florida.
Background
Petitioner and Ms. Cullen were married but living separately
during the calendar year 1999 and were divorced in September
2000. During their separation, Ms. Cullen lived in a travel
trailer situated next door to the marital residence. Petitioner
and Ms. Cullen filed a joint Form 1040, U.S. Individual Income
Tax Return, for the year 1999.
Although both petitioner and Ms. Cullen have some college-
level education, it was petitioner who collected and organized
the financial records required to prepare their joint Federal
income tax returns during their marriage. The 1999 tax return
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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