- 2 - 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.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