Helen M. Korchak - Page 43

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               At the time of the trial, the residence in which petitioner            
          and Mr. Korchak were living that petitioner owned was subject to            
          liabilities totaling $139,000.19                                            
               Petitioner filed a second petition with the Court with                 
          respect to her taxable year 1982.  In that petition, petitioner             
          claimed that she is entitled to relief under section 6015 with              
          respect to the deficiency in tax assessed against petitioner and            
          Mr. Korchak for their taxable year 1982 as well as interest                 
          thereon as provided by law.                                                 
                                       OPINION                                        
          Section 6015(b)                                                             
               Introduction                                                           
               Petitioner claims that she is entitled to relief under                 
          section 6015(b) for her taxable year 1982.20  Section 6015(b)               
          provides in pertinent part:                                                 
               SEC. 6015.  RELIEF FROM JOINT AND SEVERAL LIABILITY ON                 
                         JOINT RETURN.                                                
                  *       *       *       *       *       *       *                   
               (b) Procedures For Relief From Liability Applicable                    
               to All Joint Filers.--                                                 
                         (1) In general.--Under procedures prescribed                 
                    by the Secretary, if–                                             


               19The record does not disclose whether petitioner or Mr.               
          Korchak had any other liabilities at the time of the trial.                 
               20In the alternative, petitioner claims relief under sec.              
          6015(f) for her taxable year 1982.                                          




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