Timothy J. Glenn - Page 3

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               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.                   





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