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Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6659
1980 $28,057 $1,403 0 --
1981 47,048 2,352 1 $14,114
1982 54,293 2,715 1 16,288
1983 830 42 1 --
150 percent of the interest due on the deficiency.
The sole issue remaining for decision is whether petitioner
Cynthia A. Barnhill (Mrs. Barnhill) is entitled to relief as an
innocent spouse under section 6013(e). Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Petitioners were residents of Burbank, California, at the
time that they filed their petition. They were married on
April 15, 1960, and continuously lived together thereafter.
Mrs. Barnhill attended Pacific Lutheran University in Parkland,
Washington, completing 2 years of education in general business
and liberal arts classes. During the years in issue, however,
Mrs. Barnhill was not employed outside of the home. Joseph L.
Barnhill, Jr. (Mr. Barnhill), was a business consultant during
the years in issue.
On their joint Federal income tax returns for the years in
issue, among other things, petitioners reported the following:
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