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for relief from joint and several liability under either section
6015(b) or section 6015(c) and (2) whether respondent abused his
discretion in denying petitioner’s request for relief from joint
and several liability under section 6015(f).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
amounts have been rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time that the petition in this case was filed, petitioner resided
in New York, New York.
Background
Petitioner married George Apostle (Apostle) on May 14, 1989.
On or about June 29, 1989, petitioner sold an apartment in New
York City (New York apartment) that she owned jointly as tenants
in common with John Demirjian, petitioner’s first husband.
Petitioner realized a $564,000 gain on this sale. Both
petitioner and Apostle were under the age of 55 when the New York
apartment was sold. Petitioner and Apostle were divorced on
September 22, 1994. Apostle died in 2002.
The Original Joint Return
On or about September 24, 1990, petitioner and Apostle filed
a joint Form 1040, U.S. Individual Income Tax Return, and
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