Rhonda K. Juell, a.k.a. Rhonda K. Juell-Podlak, Petitioner, and Glenn M. Evans - Page 10




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               On May 22, 2006, petitioner timely filed a petition with               
          this Court for relief from joint and several liability with                 
          regard to the entire amount of the above tax deficiencies                   
          relating to the Hoyt partnership investments in which Glenn had             
          invested.                                                                   
               Shortly before trial, respondent agreed that petitioner                
          qualified for partial relief from joint liability under section             
          6015(c) for each year in issue, reducing the tax deficiency for             
          which petitioner is allegedly liable for each year by                       
          approximately two-thirds.                                                   
               Since her divorce in 2000, petitioner has timely filed                 
          separate individual Federal income tax returns, and no tax                  
          deficiencies for years subsequent to 1994 have been determined by           
          respondent against petitioner.                                              
               Petitioner has since remarried, and petitioner and her                 
          current husband earn approximately $100,000 a year, of which                
          petitioner earns approximately $60,000.                                     

                                       OPINION                                        
               Generally, taxpayers filing joint Federal income tax returns           
          are jointly and severally liable for all taxes due.  Sec.                   
          6013(d)(3).  However, relief from joint liability may be                    
          available in circumstances described in section 6015(b), (c), and           
          (f).                                                                        








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