Khen T. Huynh - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue.                 
               The issue for decision is whether petitioner under section             
          6015(g)(2) is barred from obtaining relief from joint liability             
          for the tax deficiencies which were sustained in Huynh v.                   
          Commissioner, supra.                                                        

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petition was filed, petitioner resided in              
          San Diego, California.                                                      
               From 1979 through 1997, petitioner worked for the County of            
          San Diego Department of Social Services as an eligibility                   
          technician, reviewing the eligibility of those seeking social               
          service benefits.  Petitioner speaks and reads English.                     
               In May of 1996, petitioner’s husband (Hong), who apparently            
          possesses numerous college and graduate degrees, including a law            
          degree, was laid off from his job.  Hong had purchased insurance            
          coverage which provided, among other things, that in the event              
          Hong became unemployed the insurers would make payments on some             
          portion of the outstanding balance due on his 11 credit cards.              
               When Hong became unemployed, the insurers began making                 
          monthly payments on his credit cards.  At the end of 1996, Hong’s           
          credit cards reflected a total outstanding balance of $91,333.              







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