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income tax evasion under section 7201, filing a false return
under section 7206(1), and conspiracy under 18 U.S.C. section
371 for the taxable year 1980. They were acquitted of the same
charges for the years 1979 and 1981.
Respondent determined that Mr. Gaskins and Mr. Quinn each
had diverted receipts from West Pine in the amounts of $46,891,
$52,819, and $154,630 for 1979, 1980, and 1981, respectively,
and adjusted the Gaskins' and the Quinns' incomes as reported on
their Federal individual income tax returns upwards accordingly.
See supra note 3. Both the Gaskins and the Quinns filed joint
Federal income tax returns for these years and, therefore,
respondent, in the notices of deficiency, determined the
resulting deficiencies against Mr. and Mrs. Gaskins jointly and
against Mr. and Mrs. Quinn jointly. However, the additions to
tax for fraud were determined only against Mr. Gaskins and Mr.
Quinn. Mr. Gaskins and Mr. Quinn have conceded the deficiencies
for all 3 years and the additions to tax for fraud for 1979 and
1980; respondent has conceded the addition to tax for fraud for
1981. Mrs. Gaskins and Mrs. Quinn seek relief in this Court from
these deficiencies as innocent spouses under section 6013(e) for
all 3 years.
Petitioner Elaine Gaskins
Background
Mrs. Gaskins was born on October 20, 1943. She graduated
from high school in 1961; she received no further formal
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