T.C. Memo. 2005-22
UNITED STATES TAX COURT
CHARMA GATLIN COOK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17166-02. Filed February 10, 2005.
R determined a deficiency in Federal income tax
with respect to the joint return for 1998 made by P and
her then husband (which determination P did not
contest); R denied P’s subsequent request for relief
from joint and several liability under I.R.C. sec.
6015(b), (c), or (f).
1. Held: P is eligible to elect relief under
I.R.C. sec. 6015(c), and R has failed to nullify the
election by demonstrating that she had actual knowledge
at the time she signed the joint return of the item
giving rise to the deficiency.
2. Held, further, R erred in denying P relief
under I.R.C. sec. 6015(c).
3. Held, further, P has no liability for the
deficiency.
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