David C. Jonson and Estate of Barbara J. Jonson, Deceased - Page 1
















                                   118 T.C. No. 6                                     


                               UNITED STATES TAX COURT                                


            DAVID C. JONSON AND ESTATE OF BARBARA J. JONSON, DECEASED,                
               DAVID C. JONSON, SUCCESSOR IN INTEREST, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 21648-87.            Filed February 8, 2002.                


                    H and W filed joint Federal income tax returns for                
               1981 and 1982 on which they took large deductions                      
               attributable to a tax shelter investment.  R disallowed                
               the deductions.  W claimed relief from joint liability                 
               under sec. 6013(e), I.R.C., which was repealed and                     
               replaced by sec. 6015, I.R.C.  W died while still                      
               married to and living with H.  Ps concede the                          
               deficiencies but pursue the sec. 6015, I.R.C. claim on                 
               behalf of W.  Ps allege that, although W was aware of                  
               the tax shelter investment, the anticipated tax                        
               savings, and the tax risks, she qualifies for relief                   
               under sec. 6015(b)(1), (c), and (f), I.R.C.  Ps allege                 
               that H, as W’s personal representative, is eligible to                 
               elect relief under sec. 6015(c), I.R.C., because, at                   
               the time he filed such election, W was “no longer                      
               married to” H. See sec. 6015(c)(3)(A)(i), I.R.C.                       








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