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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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