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petitioner relief under section 6015(f) for each of the taxable
years 1988 though 1997 and 2000. We hold that respondent abused
respondent’s discretion in denying petitioner such relief.
FINDINGS OF FACT
All of the facts in this case, which the parties submitted
under Rule 122, have been stipulated by the parties and are so
found.
Petitioner resided in Ocean City, Maryland (Ocean City), at
the time she filed the petition.
In 1978, petitioner married Michael Beatty (Mr. Beatty).
She was still married to him when the parties submitted this case
under Rule 122.
In 1975, petitioner received an associate degree from Villa
Julie College. Mr. Beatty stopped attending school when he was
in the ninth grade.
From 1975 until 1980, petitioner worked as a medical secre-
tary for Washington Hospital Center in Washington, D.C.
Around 1977, Mr. Beatty obtained a Small Business Adminis-
tration loan in order to purchase a delicatessen and bakery
business that he incorporated under the name “MKB Donut and Deli,
Inc.” (MKB). Mr. Beatty failed to pay his withholding tax
liabilities with respect to MKB, and respondent filed Federal tax
liens with respect to such liabilities. In 1980, MKB filed for
bankruptcy, and he eventually lost MKB and all of his savings.
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