- 2 -
Respondent determined a deficiency of $16,584 in the joint
Federal income tax of petitioner and petitioner’s former spouse,
Timothy J. Glenn (Mr. Glenn),1 and an accuracy-related penalty of
$3,317 pursuant to section 6662(a) for the taxable year 2001.
After concessions, the issue for decision is whether
respondent abused his discretion in denying petitioner relief
from joint and several liability for the tax deficiency and
accuracy-related penalty pursuant to section 6015.2
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.
1Timothy J. Glenn’s case at docket No. 7249-04S was tried
consecutively with petitioner’s case on this Court’s Chicago,
Illinois, session beginning Nov. 29, 2004. These cases were not
consolidated because of an objection by petitioner.
2A joint notice of deficiency was mailed to petitioner and
Mr. Glenn on Feb. 25, 2004. Mr. Glenn filed a timely petition
with this Court on Apr. 26, 2004, at docket No. 7249-04S seeking
a redetermination of the deficiency relating to the additional
tax under sec. 72(t) and the accuracy-related penalty pursuant to
sec. 6662(a). Petitioner filed her petition on June 3, 2004.
This Court has no jurisdiction to redetermine the deficiency
related to the additional tax under sec. 72(t) nor the accuracy-
related penalty pursuant to sec. 6662(a) as to petitioner’s
petition because the petition for such redetermination would be
untimely.
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