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.Page: 1 2 3 4 5 6 7 8 9 Next
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