- 3 - several liability, both in her case and as intervenor in Mr. Gilmer’s case. After the stipulations and Ms. Payton’s concession, the remaining issue before this Court is whether petitioner is entitled to relief from joint and several liability under section 6015(b), (c), or (f). Background Some of the facts are stipulated. The stipulated facts and the exhibits received into evidence are incorporated herein by reference. At the time that his petition was filed, Mr. Gilmer resided in Kansas City, Missouri. During the taxable year in issue, Mr. Gilmer was married to Ms. Payton. There were no children born of the marriage. Petitioner and Ms. Payton separated sometime in 2001 and divorced in 2004. Petitioner is employed as a schoolteacher. Petitioner and Ms. Payton filed a joint 2001 Federal income tax return. Mr. Gilmer prepared the joint income tax return reporting all sources of income, itemized deductions, and Schedule C, Profit or Loss From Business, and Schedule E, Supplemental Income and Loss. On their joint return, petitioners reported losses on Schedules C and E. The Schedule C business activity, known as World Works Diversified, encompassed two separate lines of business: the selling of hats, flags, and other Western-themed novelties, and an educational consulting activity.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007