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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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Last modified: May 25, 2011