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Year Deficiency
1987 $7,993
1988 6,710
1989 5,993
1990 7,465
1991 8,253
1992 6,787
1993 7,326
1994 2,016
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
The issue for decision is whether petitioner Rhonda Juell is
entitled to relief from joint and several liability under section
6015(b), (c), or (f) with respect to the entire amount of each of
the above tax deficiencies determined by respondent. Intervenor
Glenn Evans (Glenn) objects to petitioner’s right to any relief
under section 6015.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
St. Cloud, Minnesota.
On October 10, 1987, Glenn and petitioner were married.
In 1988, petitioner received her teaching degree and ever
since has been employed as an elementary school teacher. In
1994, the last year in issue, petitioner received a master’s
degree in education.
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