Joyce A. Siddons, Petitioner, and Richard J. Siddons, Intervenor - Page 4

                                        - 3 -                                         
          called Hoosier Painting that specialized in painting interiors              
          and exteriors of residential homes.                                         
               Petitioner and intervenor filed their 1998 joint Federal               
          income tax return timely.  The return reported wages from                   
          petitioner’s employment of $14,456 and a credit for withheld                
          Federal income tax of $1,372.  The return also included a                   
          Schedule C, Profit or Loss From Business, for intervenor’s                  
          painting business.  That activity reflected a net profit of                 
          $33,740.  The tax shown on the return was $7,563, which included            
          $4,767 of self-employment tax from intervenor’s trade or business           
               The return was prepared and filed by a certified public                
          accountant and was signed by both parties.  Respondent agrees               
          that the unpaid liability is solely attributable to intervenor’s            
               Petitioner filed Form 8857, Request for Innocent Spouse                
          Relief, with the Internal Revenue Service (IRS) on or about                 
          November 4, 2002.  The IRS subsequently denied relief, and                  
          petitioner filed a timely petition in this Court.  Petitioner’s             
          sole position is that she is entitled to relief from joint                  
          liability under section 6015.  Respondent, pursuant to Rule 325             
          and King v. Commissioner, 115 T.C. 118 (2000), served notice of             
          this proceeding on intervenor, who filed a Notice of Intervention           
          on April 19, 2004.  However, in his intervention, intervenor did            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011