Janet Marie Wilson, Petitioner, and Kenneth E. Wilson, Intervenor - Page 2




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          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.                                                                     






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