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is not reviewable by any other court, and this opinion should not
be cited as authority.
Pursuant to the provisions of section 6015, petitioner
submitted to respondent an administrative request for relief from
Federal income tax liabilities for the taxable year 2000.
Respondent determined that petitioner is not entitled to relief
from joint and several liability for $15,044 of unpaid Federal
income tax, penalties, and interest for 2000 under section
6015(f). Petitioner timely filed a petition with this Court
under section 6015(e)(1) for review of respondent’s
determination.
The sole issue for decision is whether respondent abused his
discretion in denying petitioner relief from joint and several
liability under section 6015(f). We hold that he did not.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time that the petition was filed, petitioner resided
in Mooresville, North Carolina.
Petitioner and Tracy B. Puckett (Mr. Puckett) were married
in 1987. Petitioner and Mr. Puckett began maintaining separate
residences in May 2000 and were legally separated in April 2002.
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