Patricia A. Hendricks and John J. Hendricks - Page 2

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          her request for relief from joint and several liability pursuant            
          to section 6015.  After concessions, the sole issue for decision            
          is whether respondent abused his discretion in denying                      
          petitioner’s request for relief from joint and several tax                  
          liability pursuant to section 6015 as to 1983.                              
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect at all relevant times, and                  
          amounts are rounded to the nearest dollar.                                  
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts, with accompanying exhibits, is incorporated           
          herein by this reference.                                                   
               Petitioner and Mr. Hendricks (collectively, the Hendrickses)           
          were residents of the State of Colorado at all times relevant to            
          this case.  The Hendrickses have been married for more than 45              
          years and have at all times filed joint Federal income tax                  
          returns; i.e., Form 1040, U.S. Individual Income Tax Return.                
          Both petitioner and Mr. Hendricks are more than 70 years of age             
          and are retired.  Before the Hendrickses married, they agreed to            
          separate their responsibilities, deciding that petitioner would             
          run the household while Mr. Hendricks would be responsible for              
          their finances.                                                             
               Mr. Hendricks worked as a farm manager and a farm and ranch            
          real estate broker, and he invested in real estate.  Mr.                    

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Last modified: May 25, 2011