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and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Respondent denied petitioner’s request for section 6015
relief with respect to a $6,445 deficiency in income tax and a
$929 section 6662 accuracy-related penalty assessed for
petitioner and intervenor’s taxable year 1997. The issue we must
decide is whether petitioner is entitled to relief pursuant to
section 6015(b), (c), or (f).
Background
Some of the facts and certain exhibits have been stipulated.
The parties’ stipulations of fact are incorporated in this
Summary Opinion by reference and are found as facts in the
instant case. At the time of filing the petition, petitioner
resided in Greenwood, South Carolina. Petitioner and intervenor
(collectively referred to as the Easlers) were married on August
18, 1979. Petitioner has a general education development diploma
and a certified nursing assistant’s diploma. During taxable year
1997, petitioner worked as a retail manager at C.B. Mart, Inc.
and Wal-Mart, Inc. Intervenor has taken a few college courses,
including courses in government and economics. During taxable
year 1997, Intervenor was employed as a sales clerk at Greenwood
Mills, Inc. On their 1997 tax return, the Easlers reported
$12,030.78 in wages earned by petitioner but omitted $29,506 in
wages earned by intervenor. The $29,506 in omitted wages enabled
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