Mary A. George, (2004)
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Mary A. George, (2004)
T.C. Memo. 2004-261
UNITED STATES TAX COURT MARY A. GEORGE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2380-03. Filed November 16, 2004.Mary A. George, pro se.Brianna J. Basaraba, for respondent.MEMORANDUM OPINION WELLS, Judge: Respondent determined that petitioner was not entitled to equitable relief pursuant to section 6015(f) for petitioner's 1994, 1995, 1996, 1997, 1998, and 1999 tax years.1 The issue to be decided is whether respondent's denial of petitioner's request for equitable relief pursuant to section 6015(f) was an abuse of discretion.The parties have submitted the instant case fully stipulated, without trial, pursuant to Rule 122. The parties' stipulations of fact are incorporated herein by reference and are found as facts in the instant case.At the time of filing her petition, petitioner resided in Atlanta, Georgia.During the years in issue, petitioner was married to James George. Both petitioner and Mr. George held master's degrees. Petitioner was employed as a school teacher, and Mr. George was employed by Georgia Power Company. In addition to his regular employment, Mr. George entered a business venture in 1998 to build and sell single-family homes.Petitioner and Mr. George failed to timely file income tax returns for 1994, 1995, 1996, 1997, and 1998. Mr. George, however, periodically told petitioner that he had timely filed the tax returns for those years and had paid the related tax liabilities, and respondent concedes that petitioner...See the full content of this document
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