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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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