King v. Commissioner
United States Tax Court
P and H filed a joint income tax return for 1993. P and H later divorced. R issued separate notices of deficiency to P and H determining identical deficiencies in tax for 1993 related entirely to the disallowance of a claimed business loss. P filed a petition. P's only claim was for relief as an innocent spouse under former sec. 6013(e), I.R.C. H did not file a petition.
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P and H filed a joint income tax return for 1993. P and H later divorced. R issued separate notices of deficiency to P and H determining identical deficiencies in tax for 1993 related entirely to the disallowance of a claimed business loss. P filed a petition. P's only claim was for relief as an innocent spouse under former sec. 6013(e), I.R.C. H did not file a petition. R assessed a deficiency against H who has not paid any portion of the assessment and has not challenged the assessment in any other court. Subsequent to the petition and trial in this case, sec. 6013(e), I.R.C., was repealed…
1Opinion of the Court
OPINION
Ruwe, Judge:
The matter before the Court is a motion for leave to file notice of intervention (embodying notice of intervention) by Curtis T. Freeman (Mr. Freeman) with respect to petitioner’s claim for relief from joint liability under section 6015.1
Background
Mr. Freeman was previously married to petitioner, and he and petitioner filed a joint return for 1993, which is the year in issue. Although Mr. Freeman is not a petitioner in this case, he objects to petitioner’s claim for relief from joint liability.
At the time the petition was filed, petitioner was a resident of Hartsville,…
2Cases cited4 opinions
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- Fernandez v. CommissionerUnited States Tax Court · 2000
- Corson v. CommissionerUnited States Tax Court · 2000
- Charlton v. CommissionerUnited States Tax Court · 2000
3Cited by70 opinions
- Ewing v. Comm'rUnited States Tax Court · 2004
- Porter v. Comm'rUnited States Tax Court · 2008
- Commissioner v. NealCourt of Appeals for the Eleventh Circuit · 2009
- John Maier, III v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2004
- Miller v. CommissionerUnited States Tax Court · 2000
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