- 2 - Respondent determined a deficiency of $16,584 in the joint Federal income tax of petitioner and petitioner’s former spouse, Carolyn A. Glenn (Ms. Glenn),1 and an accuracy-related penalty of $3,317 pursuant to section 6662(a) for the taxable year 2001. After concessions, the issues for decision are: (1) Whether petitioner is liable for the accuracy-related penalty pursuant to section 6662(a) for the taxable year 2001; and if so, (2) whether petitioner is entitled to relief from joint and several liability for the tax deficiency and accuracy-related penalty 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 Hoffman Estates, Illinois, on the date the petition was filed in this case. Petitioner and Ms. Glenn were married on July 8, 1989. For taxable year 2001, petitioner and Ms. Glenn filed a timely joint Federal income tax return. During the year at issue, petitioner and Ms. Glenn were married and resided in the same household; however, they occupied separate rooms in the household. Their 1Carolyn A. Glenn’s case, docket No. 9199-04S, was tried immediately after petitioner’s case on this Court’s Chicago, Illinois, session beginning Nov. 29, 2004. These cases were not consolidated because of an objection by Carolyn A. Glenn.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