Leonard W. Harbin, and Bernice Nalls, Intervenor v. Commissioner

Kroupa, Judge:

This case arises from a petition for relief from joint and several liability under section 6015 1 after respondent issued a Final Notice of Determination Concerning Your Request for Relief From Joint and Several Liability under section 6015 denying petitioner relief from deficiencies for 1999 and 2000 (years at issue). Petitioner argues that he is entitled to relief under section 6015 from liability for the portions of the deficiencies for the years at issue that are attributable to his former wife’s (intervenor) gambling activities (deficiencies at issue). We must decide…