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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 and
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Last modified: November 10, 2007