Connie J. Meadows - Page 3

                                       - 2 -                                          
        decision to be entered is not reviewable by any other court, and              
        this opinion shall not be treated as precedent for any other case.            
             This case involves innocent spouse relief for the amount of              
        tax shown as due on petitioner and her then husband’s joint 1999              
        income tax return that has not been fully paid.  Petitioner                   
        contends that respondent’s allowance of only partial innocent                 
        spouse relief was an abuse of discretion.  Consequently, we must              
        decide whether respondent abused his discretion in denying                    
        petitioner innocent spouse relief under section 6015(f) for $1,815            
        of the $7,100 shown as the amount owed on the 1999 return.                    
                                    Background                                        
             Some of the facts have been stipulated and are so found.  The            
        stipulation of facts and the attached exhibits are incorporated               
        herein by this reference.  At the time of filing the petition,                
        petitioner resided in Houston, Texas.                                         
        Petitioner and her husband at that time, Todd Meadows, timely                 
        filed a joint Form 1040, U.S. Individual Income Tax Return, for               
        1999.  They reported Mr. Meadows’s wage income of $51,825.97 and              
        petitioner’s wage income of $39,455.81, together with other income            
        items such as a taxable distribution from a pension plan, interest            
        income, and dividend income.  Their total income for 1999 was                 
        shown as $107,208.  The total tax shown was $20,395, with $7,100              
        owed (including a $256 estimated tax penalty).                                







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011