Dwan A. Thomas - Page 3

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               Respondent determined petitioner was not entitled to relief            
          from joint and several liability for a $6,450 underpayment of tax           
          for tax year 2000 pursuant to section 6015.  The issue for                  
          decision is whether respondent abused his discretion by denying             
          petitioner’s request for relief from joint and several liability            
          under section 6015 for the 2000 underpayment of tax.                        
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received into evidence            
          are incorporated herein by reference.  At the time the petition             
          was filed with the Court, petitioner resided in Jacksonville,               
          Florida.                                                                    
                                     Background                                       
               Petitioner was married to Shannon R. Flowers (Mr. Flowers),            
          and one child was born during the marriage.  They were legally              
          married during 2000, but divorced in 2002.                                  
               Petitioner is a college graduate with a bachelor of science            
          degree in health information management.  During 2003, she was              
          enrolled in a master of business administration program at                  
          Webster University.  During 2000, petitioner was employed as a              
          director with Shands Jacksonville.                                          
               Mr. Flowers was a high school graduate in 2000 with some               
          college coursework.  He worked in automotive sales.                         
               Respondent assessed a $6,450 deficiency due to a                       
          mathematical or clerical error adjustment to the 2000 return.               






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