Helen E. Foy - Page 8

                                        - 8 -                                         
               On February 11, 2003, respondent’s answer to petitioner’s              
          petition was filed.  In his answer, respondent denied, without              
          qualification, the representation in subparagraph 6.p. and denied           
          the representations in subparagraphs 6.q. and r. “for lack of               
          knowledge or information.”                                                  
               On February 23, 2004, this case was called for hearing                 
          during the Seattle, Washington, trial session.  The parties                 
          reported that they believed they had a basis for settlement but             
          were awaiting final Government approval.  The case was scheduled            
          for recall on March 2, 2004.  At the recall, the parties reported           
          that the case had been settled and requested until April 1, 2004,           
          to submit a signed decision document.  On April 2, 2004, the                
          parties submitted a signed decision document, which we filed as a           
          stipulation of settled issues.  The stipulation of settled issues           
          reflected that the parties had agreed to a section 6015(c)                  
          allocation with respect to petitioner’s and Mr. Foy’s 1981-1986             
          income tax liabilities as follows:                                          
                           Joint tax liability         Petitioner’s share             
               Year         before allocation          under sec. 6015(c)             
               1981        $22,995.36                       -0-                       
               1982        22,461.15                        -0-                       
               1983        24,280.00                        -0-                       
               1984        8,057.93                         $51.46                    
               1985        14,902.52                        -0-                       
               1986           10,607.08                     -0-                       
                    Total     103,304.04                    51.46                     
          The allocation of liability under section 6015(c) was made by               






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011