-2- did not. Cindy L. Butler (Butler) also requests relief from joint and several liability under section 6015(b), (c), or (f).1 We hold that Butler does not qualify for any relief under section 6015. FINDINGS OF FACT Some facts are stipulated and are so found. The stipulated facts and the exhibits submitted therewith are incorporated herein by this reference. Petitioners Charles Roy Schwendeman (Schwendeman) and Butler were husband and wife throughout 2002, and they filed a joint Federal income tax return for 2002. Butler and Schwendeman divorced in 2003, and each resided in Colorado when this petition was filed. In 2002, Butler was employed by IBM as an associate project manager, and Schwendeman was employed as a psychologist. Schwendeman holds a master’s degree, and Butler has completed some college courses. During 2002, petitioners shared household expenses. They were signatories on each other’s accounts, and they had access to each other’s accounts. 1 Unless otherwise indicated, section references are to the applicable versions of the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure. Although the issue as to relief under sec. 6015 was not raised by the pleadings, that issue was tried by the parties’ express or implied consent. We consider that issue to be properly before us. See Rule 41(b).Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007