Cheryl Kunsman - Page 3
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Revenue Code of 1986, as amended, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
This case arises from a petition for judicial review of the
denial of petitioner’s request for relief from joint and several
liability for 1999. The issue for decision is whether petitioner
is entitled to relief under section 6015(b), (c), or (f).
Some of the facts have been stipulated by the parties and
are so found. The stipulation of facts, with accompanying
exhibits, is incorporated herein by this reference.
At the time the petition was filed, petitioner resided in
Ocala, Florida. Petitioner and Raymond Kunsman (hereafter
referred to as Mr. Kunsman or former spouse) married in 1993.
Petitioner invested her savings to start a retail floral and gift
shop business in 1996, and she conducted her business throughout
the year at issue.
Mr. Kunsman became unemployed in 1998, and he began drinking
heavily. Mr. Kunsman started hiding financial details from
petitioner and took over the financial aspects of petitioner’s
business. During 1998, he received a lump-sum distribution from
his retirement account, the majority of which was rolled over
into an Individual Retirement Account (IRA). Mr. Kunsman
withdrew funds from the IRA in 1999 and 2000 in the amounts of
$29,925 and $51,518, respectively. At the time the distributions
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Last modified: November 10, 2007