Phyllis E. Campbell - Page 22

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          from year to year, and thus experience some years with large                
          taxes or others with no tax”).                                              
               Accordingly, we hold that petitioner did not have reason to            
          know that the London straddle deduction was illegitimate,                   
          nor did she have a duty to inquire into the presence of the                 
          deduction on the 1983 income tax return.                                    
               2.  Section 6015(b)(1)(D):  Inequity                                   
               We take into account all the facts and circumstances in                
          deciding whether it is inequitable to hold the relief-seeking               
          spouse liable for a deficiency.  Sec. 6015(b)(1)(D).  Because               
          this requirement is similar to the requirement of former section            
          6013(e)(1)(D), cases interpreting that former section such as               
          Erdahl v. Commissioner, 930 F.2d 585 (8th Cir. 1991), remain                
          instructive to our analysis.  Butler v. Commissioner, 114 T.C.              
          276, 283 (2000).  The material factors most often cited and                 
          considered are whether there has been a significant benefit to              
          the spouse claiming relief and whether the failure to report the            
          correct tax liability on the joint tax return results from                  
          concealment, overreaching, or any other wrongdoing on the part of           
          the other spouse.  Alt v. Commissioner, 119 T.C. at 314; Jonson             
          v. Commissioner, 118 T.C. at 119.  Normal support is not                    
          considered a significant benefit.  Jonson v. Commissioner, supra            
          at 114.                                                                     







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