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issue for decision is whether respondent abused his discretion in
denying petitioner’s request for equitable relief under section
6015(f).
FINDINGS OF FACT
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.2 At the time she filed
her petition, petitioner resided in Brunswick, Ohio.
Petitioner and David C. Crouch (Mr. Crouch) were married on
December 31, 1992. At the time of trial, petitioner and Mr.
Crouch remained married and continued to reside in the same
residence.
Petitioner and Mr. Crouch are graphic design artists.
During the years at issue, Mr. Crouch owned and operated Dave
Crouch Graphics. Mr. Crouch made no estimated tax payments on
income he received from Dave Crouch Graphics. During the years
at issue, petitioner was employed by Advanstar Communications,
Inc. (Advanstar). Advanstar withheld Federal income tax from
petitioner’s wages, and had she filed her returns as married
2 Respondent reserved relevancy objections to three
exhibits attached to the stipulation of facts and to all trial
testimony on the basis that such information was not available to
the Appeals officer when she made her determination in this case.
While the relevance of some of the disputed exhibits and
testimony is limited, the Court will give the evidence only such
consideration as is warranted by its pertinence to the Court’s
analysis of the instant case.
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