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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined the following
deficiencies in petitioners' Federal income tax and additions to
tax:
Additions to Tax
Year Deficiency Sec. 6653(a)
1976 $49,828 $2,491
1977 21,612 1,091
1978 12,453 623
Respondent also determined additional interest under section
6621(c) for each year as a result of substantial underpayments of
income tax attributable to tax motivated transactions.
After concessions, the only remaining issue for decision is
whether petitioner Arlene B. Epstein (petitioner or Arlene) is
entitled to claim innocent spouse status under the provisions of
section 6013(e) for each of the 3 years in issue (the relevant
years).
All section references, unless otherwise specified, are to
sections of the Internal Revenue Code in effect for the relevant
years, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners resided in Atlantic Beach,
New York, when they filed their petition.
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Last modified: May 25, 2011