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Tier II consideration: Based on the above facts it is
equitable to hold the RS
liable for the balance. RS
failed to establish marital
status or economic hardship,
there are no extenuating
circumstances such as abuse,
poor health or legal
obligation and RS had reason
to know.
Tier II factors not met - deny
Claim denied under IRC 6015(f) - full scope
CONCLUSION
1982 - Denied under 6015(b),(c),(f) [Reproduced
literally.]
At the time of the trial, petitioner and/or Mr. Korchak
owned the following properties:
Owner Type of Property Value
Petitioner Personal Residence1 $750,000
Petitioner IRA 195,220
Petitioner Investment Insurance Trust 9,509
Petitioner 1999 Saturn Automobile 3,500
Petitioner Checking Account 59,000
Petitioner House Contents 10,000
Petitioner CRI2 1,000
Petitioner Annuity Contract 466,345
Petitioner and Joint Checking Account 28,000
Mr. Korchak
Mr. Korchak IRAs 448,595
Mr. Korchak Boat 1,000
Total $1,972,169
1From Aug. 15, 1986, until Sept. 14, 1987, petitioner and Mr. Korchak
owned as tenants by the entirety the residence in which they were living. On
Sept. 14, 1987, for estate planning reasons, Mr. Korchak transferred to
petitioner for no consideration his interest in the residence in which they
were living.
2The record does not indicate what “CRI” means.
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