Susan L. Castle, (2002)
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Susan L. Castle, (2002)
T.C. Memo. 2002-142
UNITED STATES TAX COURT SUSAN L. CASTLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10195-00. Filed June 6, 2002.Gino Pulito, for petitioner.Katherine Lee Kosar and Dennis G. Driscoll, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: This case arises from a request for equitable relief (relief) under section 6015(f)1 with respect to petitioner's taxable year 1993. We must decide whether respondent abused respondent's discretion in denying petitioner relief under that section for that year. We hold that respondent did not abuse respondent's discretion.FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner resided in Las Vegas, Nevada, at the time she filed the petition.Petitioner is a high school graduate and has completed approximately 1-1/2 years of college at Lorain Community College and Columbus State. During the year at issue, petitioner worked full-time for BMW Financial Services and part-time for Dairy Queen. On October 31, 1993, petitioner married Roger L. Castle (Mr. Castle). At the time of the trial in this case, petitioner worked for Continental Airlines as a flight attendant.On August 17, 1994, petitioner and Mr. Castle signed Form 1040, U.S. Individual Income Tax Return (return), for their taxable year 1993 (1993 joint return).2 On that date, John Obrig signed the 1993 joint return as the paid preparer of that return. The 1993 joint return showed...See the full content of this document
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