Eugene McClelland and Ione McClelland - Page 2

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          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.                                                              






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