Joan Phyllis Levy - Page 2

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          and 1999.1  The issues for decision are:  (1) whether petitioner            
          is entitled to relief under section 6015(b) or (c) with respect             
          to 1979; and (2) whether respondent abused his discretion in                
          denying petitioner relief under section 6015(f) with respect to             
          each of petitioner’s taxable years 1979, 1991, 1992, 1993, 1994,            
          1995, 1996, 1997, 1998, and 1999.                                           
                                  FINDINGS OF FACT2                                   
          A.  Background                                                              
               At the time her petition was filed petitioner resided in               
          Miami-Dade County, Florida.  Petitioner received a bachelor of              
          arts degree in elementary education in 1969.  Shortly after                 
          obtaining her bachelor’s degree, petitioner worked as a                     
          substitute teacher for approximately a year.                                
               Petitioner and her former husband, Dr. Mitchell Levy (Levy),           
          married during 1974.  Petitioner and Levy had three children                




               1 References to sec. 6015 are to that section as added to              
          the Internal Revenue Code by the Internal Revenue Service                   
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201,           
          112 Stat. 734.  Sec. 6015 generally applies to any liability for            
          tax arising after July 22, 1998, and any liability for tax                  
          arising on or before July 22, 1998, that remains unpaid as of               
          such date.  See Cheshire v. Commissioner, 115 T.C. 183, 189                 
          (2000), affd. 282 F.3d 326 (5th Cir. 2002); H. Conf. Rept. 105-             
          599, at 251 (1998), 1998-3 C.B. 747, 1005.  All other section               
          references, unless otherwise indicated, are to the Internal                 
          Revenue Code in effect for the years in issue.                              
               2 Some of the facts have been stipulated and are found                 
          accordingly.                                                                




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