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Petitioner and his former spouse reported underpayments of
tax in the amount of $19,869 and $5,850 for 2000 and 2001,
respectively. No notice of deficiency was issued for either of
these taxable years. This case involves petitioner’s election to
seek relief from joint and several liability for Federal income
tax for the years 2000 and 2001 under section 6015(f).
Respondent determined that petitioner is not entitled to relief.
The sole issue for decision is whether petitioner is entitled to
relief under section 6015(f).
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Bainbridge Island, Washington.
During the years at issue, petitioner was married to
Juliette C. Peet (Ms. Peet). Petitioner and Ms. Peet married
sometime in June 1995. They separated in June 2001, and their
divorce was finalized on January 11, 2002. Petitioner was
employed as an art teacher by the Art Institute of Seattle for
taxable years 2000 and 2001. Additionally, he received income
from work he performed as a children’s illustrator for
Interactive Arts, a business he wholly owned and whose activities
were reported on a Schedule C, Profit or Loss From Business, of
the income tax returns for the years at issue. Ms. Peet worked
as a designer during taxable years 2000 and 2001.
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