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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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Last modified: November 10, 2007