Kathleen E. Gilliam - Page 3

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               Respondent determined a deficiency in petitioner’s Federal             
          income tax for the taxable year 2000 of $668.  The issues for               
          decision are:  (1) Whether petitioner is entitled to relief under           
          section 6015(b) or (c); and (2) whether respondent abused his               
          discretion in denying petitioner’s request for relief from joint            
          and several liability under section 6015(f).                                
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Lexington, North Carolina, at the time she            
          filed the petition herein.                                                  
               Petitioner was married to Max Gilliam in 1992.  In July                
          2000, Mr. Gilliam and petitioner separated.  Petitioner remained            
          in the marital residence until sometime in 2001.  Sometime in               
          2002 Mr. Gilliam and petitioner were divorced.                              
               During the taxable year 2000, Mr. Gilliam received wages of            
          $18,034, and petitioner received wages from three separate                  
          employers totaling $4,464.  Petitioner filed a joint Federal                
          income tax return with Mr. Gilliam for the taxable year 2000                
          sometime in January 2001.  The joint return was prepared by Mr.             
          Gilliam and signed by both petitioner and Mr. Gilliam.  The                 
          return reported wage income of $18,034.  Attached to the return             
          were four Forms W-2, Wage and Tax Statement.  One of the Forms W-           
          2, reflecting wages of $18,034, was issued to Mr. Gilliam.  The             

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