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, spouses
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011