Christine Ann Elliott - Page 3




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          Revenue Code in effect for the year in issue, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            
               This case involves petitioner’s election to seek relief from           
          joint and several liability for Federal income tax for the tax              
          year 2001.  The issue for decision is whether petitioner is                 
          entitled to relief under section 6015(b), (c), or (f).                      
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time of the filing           
          of the petition, petitioner resided in Kentfield, California.               
               Petitioner has a history of temporal lobe epilepsy and is              
          borderline learning disabled in arithmetic.  When petitioner was            
          17 years old, she underwent involuntary electric shock treatment            
          after her parents admitted her to a hospital.  Petitioner alleges           
          that the electric shock treatment left her with dyslexia, short-            
          term and long-term memory loss, cognitive deficiencies, and                 
          seizure disorders for which she has had to compensate for the               
          past 34 years.                                                              
               Petitioner married Kirk Elliott in 1999.  During tax year              
          2001, petitioner held an individual retirement account (IRA) in             
          her own name with the Resources Trust Company.  Petitioner had              
          been married previously, and her first husband established the              
          account for her pursuant to their divorce settlement.  During tax           







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