Janet Marie Wilson, Petitioner, and Kenneth E. Wilson, Intervenor - Page 11




                                       - 11 -                                         
          receipts.7  Accordingly, we hold that petitioner is entitled to             
          relief from joint and several liability under section 6015(c) for           
          the years in issue.                                                         
               In reaching our holding herein, we have considered all                 
          arguments made, and, to the extent not mentioned above, we                  
          conclude that they are moot, irrelevant, or without merit.                  
               To reflect the foregoing,                                              


                                                       Decision will be               
                                                  entered for petitioner.             




















               7  Even if petitioner had actual knowledge, the regulations            
          would excuse her from disqualification based on actual knowledge            
          because of the abuse present in her relationship with intervenor.           
          See sec. 1.6015-3(c)(2)(v), Income Tax Regs.                                






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11

Last modified: November 10, 2007