Dorothy Ann Magee - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               WHERRY, Judge:  This proceeding arises from a petition filed           
          in response to a Notice of Determination Concerning Collection              
          Action under Section 6330 and a Notice of Determination                     
          Concerning Your Request for Relief pursuant to section 6015(f).1            
               The issues for decision are:                                           
               (1) Whether petitioner was required to file a Federal income           
          tax return for 1996;                                                        
               (2) whether respondent abused his discretion in determining            
          that collection action under section 6330 was appropriate; and              
               (3) whether respondent abused his discretion in denying                
          petitioner’s request for relief from joint and several liability            
          under section 6015(f).                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.  At the time this petition           
          was filed, petitioner resided in Las Vegas, Nevada.                         
          I.   Background                                                             
               Petitioner and Keith R. Magee (Mr. Magee) were married, but            
          they separated at some time during calendar year 1996.                      
          Petitioner and Mr. Magee had a daughter during their marriage who           

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code (Code) in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              


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