- 2 - 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 arePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011