- 2 - 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, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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