- 2 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007