Robby Goodale Gilbert - Page 3

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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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Last modified: May 25, 2011