Julian O. Von Kalinowski and Penelope J. Von Kalinowski, (2001)
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Julian O. Von Kalinowski and Penelope J. Von Kalinowski, (2001)
T.C. Memo. 2001-21
UNITED STATES TAX COURT JULIAN O. VON KALINOWSKI AND PENELOPE J. VON KALINOWSKI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 46200-86. Filed January 30, 2001.Philip R. Linsley, for petitioners. David R. Jojola, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: For 1981 and 1982, respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:Additions to Tax Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) 1981 $182,296 $9,114.801 After concessions,1 the sole issue for decision is whether petitioner wife is entitled to relief from joint and several liability under section 6015(b)(1).2 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. References to petitioner in the singular are to Penelope J. Von Kalinowski.FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time they filed their petition with the Court, petitioners were residents of Los Angeles, California.Petitioners jointly filed a Form 1040, U.S. Individual Income Tax Return, for each of the taxable years at issue. With respect to taxable year 1981, petitioners twice filed an amended ...See the full content of this document
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