- 3 -
insurance consultant for State Farm. In this latter position,
Mr. Elias was an employee. Throughout the years, petitioner
continued in her employment as a claims adjuster for State Farm.
In the latter part of the year 2000, Mr. Elias became ill with
viral encephalitis, a serious illness that resulted in his
becoming totally and permanently disabled. His employment with
State Farm ended, and, likewise, petitioner, in November 1999,
terminated her employment with State Farm.
The notice of deficiency for 1999, referred to earlier, was
issued after petitioner and Mr. Elias were divorced. Mr. Elias
filed a petition with this Court, challenging the deficiency in
docket No. 2963-03. Petitioner, in this case, also filed a
petition and challenged the deficiency and further alleged that,
if the determinations in the notice of deficiency were sustained,
she should be relieved from joint liability under section 6015.
In lieu of proceeding to trial on the various determinations in
the notice of deficiency, petitioner and respondent agreed, in a
stipulation, that petitioner would be bound by the outcome (the
decision to be rendered) in the case of Mr. Elias, docket No.
2963-03, to the extent the deficiency did not exceed $7,977 (the
deficiency determined in the notice of deficiency). Prior to
trial of this case, Mr. Elias settled his case, and a decision
was entered in that case for a deficiency of $7,977. As a result
of the closing of the case of Mr. Elias and the stipulation of
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011