- 2 - accuracy-related penalties under section 6662(a) as follows:1 Year Deficiency Sec. 6662(a) Penalty 2001 $22,178 $4,436 2002 8,669 1,734 The sole issue for decision is whether petitioner is entitled to relief from joint and several liability under section 6015(c) for 2001 and 2002 (the years in issue). 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. At the time she filed her petition, petitioner resided in Hawaii. At the time he filed his notice of intervention, intervenor resided in Nevada. Petitioner and intervenor were married on or about February 4, 1984. They legally separated in February 2003, and on September 23, 2004, the Superior Court of Arizona, Maricopa County, officially dissolved their marriage. Throughout their marriage, intervenor physically and verbally abused petitioner and petitioner’s son. During the years in issue, the abuse included threats against petitioner’s 1 All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. All amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007