- 2 - filed. Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case. Unless otherwise indicated, subsequent section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. In a joint notice of deficiency mailed to petitioners, respondent determined a deficiency in petitioners’ 2001 Federal income tax of $11,747 and an accuracy-related penalty of $2,349.40 pursuant to section 6662(a). Each petitioner filed a separate petition. Webber Douglas Gilmer’s (petitioner) petition seeks a redetermination of the deficiency and the accuracy-related penalty, and his amended petition seeks relief from joint and several liability on their joint return for 2001 pursuant to section 6015. Minnie Ruth Payton’s (Ms. Payton) petition also seeks relief from joint and several liability on their joint return for 2001. Each petitioner filed a notice of intervention in the other’s case. When these cases were called for trial, the parties in each filed a stipulation of settled issues. In the stipulation, petitioners stipulated a deficiency for 2001 in the amount of $5,722, and an accuracy-related penalty of $1,144. Further, Ms. Payton, at trial, conceded her claim for relief from joint andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007