Harvey I. Epstein and Arlene B. Epstein - Page 2

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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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