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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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Last modified: May 25, 2011