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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