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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
For 2002, the year at issue, petitioner was married to
Brenda S. Maggio. They filed a joint Federal income tax return
for the year at issue. In the examination of the return for
2002, petitioner’s spouse agreed to a deficiency of $27,847 in
tax. Petitioner, however, did not agree to the proposed
deficiency. Accordingly, a notice of deficiency was issued
solely to him for the deficiency of $27,847. No notice of
deficiency was issued to petitioner’s spouse because of her prior
concession of the deficiency.
In his petition to this Court, petitioner does not challenge
the deficiency and seeks only relief from joint liability under
section 6015. At trial, petitioner and respondent filed a
Stipulation of Settled Issues wherein petitioner conceded the
deficiency of $27,847. Respondent, in turn, conceded that
petitioner was entitled to relief from joint liability for the
year at issue under section 6015(c). Thus, there is no
justiciable issue between petitioner and respondent. The sole
issue is the intervention filed by petitioner’s former spouse,
Brenda S. Stringer, who opposes the granting of section 6015
relief to petitioner.
Some of the facts were stipulated and are so found. The
stipulation of facts and the accompanying exhibits are
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