claimed refunds in the amount of $10,180, $9,620, and $700 for the taxable years 1980, 1981, and 1982, respectively. 4. The Notice of Deficiency In the notice of deficiency, respondent disallowed the Saxon deductions claimed by petitioners on their Schedule C for equipment leasing and management expenses in the amount of $14,168. In the notice of deficiency, respondent also disallowed the investment tax credit claimed by petitioners on Form 3468 in the amount of $20,500. ULTIMATE FINDING OF FACT In signing the joint income tax return for 1983 and the application for refund, petitioner had reason to know that there were substantial understatements of tax attributable to grossly erroneous items. OPINION 1. Background The parties have resolved all of the issues in this case except whether petitioner qualifies for relief as an innocent spouse under section 6013(e) for the 2 taxable years in issue. Section 6013(a) permits a husband and wife to file a joint income tax return. This is a valuable privilege because the filing of a joint return generally serves to decrease the spouses' overall tax liability. Sec. 1. The privilege of filing a joint income tax return does not come without a price, however. Thus, as a general rule, spousesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011