T.C. Memo. 2007-234
UNITED STATES TAX COURT
DAVID BRUCE BILLINGS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6148-03. Filed August 16, 2007.
Patrick Wiesner, for petitioner.
Vicki L. Miller, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HOLMES, Judge: David Billings, the petitioner, began this
case to be relieved from liability for the tax owed on money that
his wife embezzled from her employer without his knowledge. When
this case was first before us, we dismissed it for lack of
jurisdiction. Billings v. Commissioner, 127 T.C. 7 (2006)
(Billings I). Billings appealed our decision and, while his
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Last modified: November 10, 2007