- 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 Next
Last modified: November 10, 2007