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Respondent determined a deficiency in petitioner and his
former spouse’s Federal income tax of $3,280.10 for 1999. The
issue for decision is whether petitioner is entitled to relief
from joint or several liability pursuant to section 6015(b), (c),
or (f).
Background
The stipulated facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
in this case was filed, petitioner resided in Mesa, Arizona.
Petitioner and his former spouse, Leanne Valentine Packer
(Ms. Valentine), were married in 1996. Petitioner and Ms.
Valentine separated in August of 1999. Petitioner is a college
graduate. During 1999, he was employed by the U.S. Postal
Service. Ms. Valentine is a high school graduate. During the
relevant periods in 1999, she was employed as a receptionist for
an orthodontist. In 1999, Ms. Valentine received a distribution
from her 401(k) account in the amount of $32,802 (distribution).
On February 8, 2000, petitioner filed a Petition for
Dissolution of Marriage (Divorce) Without Children in the
Superior Court of Arizona. On April 15, 2000, petitioner and Ms.
Valentine jointly filed a Form 1040, U.S. Individual Income Tax
Return, for 1999, which was prepared by a certified public
accountant. The distribution was reported as income on the
return. On July 27, 2000, the Superior Court of Arizona entered
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