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liability triggered by that income. Sec. 6015(b)(1)(B); Hopkins
v. Commissioner, 121 T.C. 73, 77 (2003).9
Conclusion
Linda was responsible for the income from Dela’s Demos, and
does not qualify for relief for that portion of the tax
liability. She does, however, qualify for relief under section
6015(b) for the much larger part of the tax liability caused by
Jerry’s embezzlement.
A decision will be entered
under Rule 155.
9 Though, strictly speaking, Linda's failure to prove
entitlement to relief under section 6015(b) for her Dela's Demos
income leaves open the possibility of relief under section
6015(f), she does not argue that the Commissioner abused his
discretion in denying her relief for that small part of the
deficiencies, nor do we see how she could.
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