- 2 - 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). Background 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 distributionsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007