- 2 - consolidated. In a stipulation of settlement, the parties agreed to deficiencies of $265,255 for 1997 and zero for 1998. The sole remaining issue in this case is whether petitioner Ione McClelland (Ms. McClelland) is entitled to relief from joint and several liability pursuant to section 6015(b)1 or, in the alternative, under section 6015(f). Respondent concedes this issue, but petitioner Eugene McClelland (Mr. McClelland) opposes such relief. As explained herein, we find Ms. McClelland is entitled to relief under section 6015(b). FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and attached exhibits are incorporated herein by this reference. During the tax years in issue, petitioners resided in Red Wing, Minnesota. Ms. McClelland’s General Background Ms. McClelland was born on May 15, 1940, and graduated from high school in May 1958. Ms. McClelland married Mr. McClelland on February 14, 1959. In the summer of 1959, Ms. McClelland was trained as a flight attendant. However, during 1959 and early 1960, she worked as a waitress. From sometime in 1960 until 1967, she 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect during the years 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 Next
Last modified: May 25, 2011