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This case arises from a request for relief under section
6015 with respect to unpaid taxes reported on joint returns filed
by petitioner and her former spouse for tax years 1995, 1997, and
1998. Respondent determined that petitioner was not entitled to
any relief under section 6015. Petitioner timely filed a
petition seeking review of respondent’s determination.
The issue for decision is whether petitioner is entitled to
relief from joint and several liability for the taxable years
1995, 1997, and 1998, pursuant to section 6015.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Ahoskie, North Carolina, on the date the petition was filed in
this case.
Petitioner and her former spouse, David A. Tillotson (Mr.
Tillotson), were married on April 29, 1990. During 1995, 1997,
and 1998, the years in issue, petitioner was married to Mr.
Tillotson.
During 1995, petitioner was employed by JCPenney Life
Insurance and Graphic Products, Inc. During 1995, Mr. Tillotson
was employed by Draperies and More, Inc. JCPenney Life Insurance
prepared a 1995 Form W-2, Wage and Tax Statement, for petitioner
indicating wage income of $5,525.90 and Federal income tax
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