Pamela J. Ellison, (2004)
Linked as:
Extract
Pamela J. Ellison, (2004)
T.C. Memo. 2004-57
UNITED STATES TAX COURT PAMELA J. ELLISON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11718-02. Filed March 9, 2004.Terri A. Merriam, Wendy S. Pearson, and Jennifer A. Gellner, for petitioner.Margaret A. Martin, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: Respondent determined that petitioner did not qualify for relief from joint and several liability pursuant to section 6015(b), (c), or (f).1 The issue for decision is whether petitioner is entitled to relief from joint and several liability pursuant to section 6015(b) or (f) for 1982, 1983, 1984, 1985, and 1986.2 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The first stipulation of facts, second stipulation of facts, third stipulation of facts, and the attached exhibits are incorporated herein by this reference. At the time she filed the petition, petitioner resided in Monroe, Michigan.Petitioner and Her Husband Petitioner has a high school education that, since 1991, she has supplemented with some college courses in bank management.Petitioner married Don Ellison (Mr. Ellison) in 1971. As of the date of trial, petitioner and Mr. Ellison were married and living together. Mr. Ellison is currently employed as an inspector at the Ford Motor Co.From 1971 to 1988, petitioner mainly worked part-time jobs. In 1986, however, she worked full time as a bank teller. Since 1990, petitioner has worked full time as a collections supervisor at a financial institution.As of the time of trial, petitioner was 48 years old and in good health.Petitioner's Relationship With Mr. Ellison Mr. Ellison did not conceal anything from petitioner. Mr. Ellison did not deceive petitioner. Mr. Ellison did not hide, or try to hide, any informati...See the full content of this document
Sponsored links
