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petitioner was not entitled to relief for a $4,850 underpayment
of tax for tax year 1996 pursuant to section 6015. The issue for
decision is whether respondent abused his discretion by denying
petitioner's request for relief from joint and several liability
under section 6015(f) for the 1996 underpayment of tax.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
was filed with the Court, petitioner resided in Baltimore,
Maryland.
FINDINGS OF FACT
Petitioner married in 1980 and bore four children during the
marriage. As of the time of respondent's determination, in June
of 2001, three of the children were still minors. Petitioner has
an eleventh grade education and was primarily a homemaker.
During 1996, petitioner worked part time, earning $7,875 from
which taxes were withheld. Petitioner's spouse, William A.
Keitz, owned and operated his own electrical business, A.K.
Electric. Petitioner had no involvement at all with Mr. Keitz's
business. During their marriage, Mr. Keitz handled the family
financial matters. He gave petitioner a weekly amount to cover
food and other necessities and an allowance of $60 per week for
herself. When the children needed clothes, Mr. Keitz would give
petitioner additional money. Mr. Keitz demanded that petitioner
not open any bills that came in the mail and that if she did, he
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