- 2 - 1981 Federal income tax.1 In Golden v. Commissioner, T.C. Memo. 2005-170, the Court decided for respondent through partial summary adjudication all issues in this case, but for the correctness of respondent’s denial of a section 6015 claim to relief (spousal relief) made by Judith A. Golden (petitioner). We now decide whether respondent abused his discretion in denying petitioner’s claim to spousal relief.2 We hold he did not. FINDINGS OF FACT Petitioner and Robert H. Golden (Golden) are married and resided in Southfield, Michigan, when their petition was filed with the Court. Petitioner holds a college degree and worked as an elementary schoolteacher from 1964 to 1969. In 1984, she completed a course in income tax preparation. Golden is a practicing attorney and has practiced law since 1961. In the mid-1970s, Golden invested in a partnership on behalf of petitioners. Petitioners were each limited partners in the partnership, and they each received annual reports from the 1 Unless otherwise noted, section references are to the applicable versions of the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure. 2 Petitioners invite the Court also to decide an issue as to the proper interest rate applicable in this case. We decline to do so. As just noted, the Court decided in Golden v. Commissioner, T.C. Memo. 2005-170, that respondent will prevail in this case if the Court holds for respondent as to the spousal relief claim. We also note that petitioners are deemed to have stipulated under Rule 91(f) that the only issue left to be decided is whether petitioner is entitled to spousal relief.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007