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seeks relief from respondent’s determination of a joint and
several tax liability (including interest) of $2,884,120.91. As
explained herein, we find petitioner is entitled to relief under
section 6015(b).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact are incorporated herein by this
reference. Petitioner resided in Lampe, Missouri, at the time her
petition was filed. Petitioner has been married to Ronald
Campbell (Mr. Campbell) since 1968. Petitioner has an
undergraduate degree in sociology and a master’s degree in
special education. In addition, petitioner obtained a licensed
practical nurse (LPN) certification in 1994. During the year at
issue, petitioner was primarily a homemaker. At the present
time, petitioner is employed at Skaggs Community Hospital as an
LPN.
Petitioner’s Relationship With Ronald Campbell
Petitioner did not participate in and had little knowledge
of Mr. Campbell’s business matters. Mr. Campbell was a
commodities broker and trader. During their marriage, petitioner
paid the household expenses from her personal checking account
that Mr. Campbell funded through wire transfers from a
1(...continued)
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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