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In a notice of deficiency to petitioner and her former
spouse, James B. Clark (Mr. Clark), respondent determined income
tax deficiencies, an addition to tax, and penalties as follows:
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1998 $ 7,494 $776.75 $1,498.80
2000 14,163 -- 2,832.60
2001 5,754 -- 1,150.80
The sole issue for decision is whether, under section 6015,
petitioner is entitled to relief from joint liability for the
above deficiencies, addition to tax, and penalties.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and are made part hereof.
Petitioner’s legal residence at the time the petition was filed
was West Valley City, Utah.
During the years at issue, petitioner was married to Mr.
Clark. The two filed joint Federal income tax returns for 1998,
2000, and 2001. Petitioner and Mr. Clark were divorced on
September 26, 2003. On March 1, 2004, respondent issued a notice
of deficiency jointly to petitioner and Mr. Clark in which the
above deficiencies, addition to tax, and penalties were
determined. Mr. Clark filed a petition with this Court, in his
own behalf, for a redetermination of the adjustments in the
notice of deficiency. That case proceeded to trial, and the
Court sustained respondent on all determinations in the notice of
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