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Code as in effect at the time the petition was filed. Unless
otherwise indicated, subsequent section references are to the
Internal Revenue Code of 1986 as amended. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority.
This case arises from petitioner’s election to seek relief
from joint and several liability for Federal income tax for the
taxable year 2001 under section 6015(f). Respondent determined
that petitioner was not entitled to such relief. The sole issue
before this Court is whether petitioner is entitled to relief
under section 6015(f) for 2001 for an underpayment of tax shown
on the return.
Background
Some of the facts are stipulated. The stipulated facts and
the exhibits received into evidence are incorporated herein by
reference. At the time that the petition was filed, petitioner
resided in Wilmington, Delaware.
Petitioner and Ebrehem Khalil Aly (Mr. Khalil Aly), an
Egyptian national, met over the Internet sometime in 1996 and
began a romantic relationship soon thereafter that spanned the
next 5 years. Mr. Khalil Aly was married with children and
living in Egypt at the time that he began an “online”
1(...continued)
for the year 2001. Therefore, this Court has jurisdiction to
decide this case.
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Last modified: May 25, 2011