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