Harvey I. Epstein and Arlene B. Epstein - Page 7

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          number of years, but of the amount she received she gave Harvey             
          $34,000 "to pay IRS taxes".  She also used most of the money to             
          pay her father's nursing home expenses, and kept $30,000 which              
          she used to rehab the Atlantic Beach house.                                 
               The art work which Arlene bought with her own earnings had a           
          total cost over the years of less than $10,000.  When Arlene                
          applied for a home improvement loan on the Atlantic Beach house             
          on August 5, 1987, the balance sheet supporting her application             
          for a variable rate $70,000 loan reflected a $100,000 value for             
          her art collection.  The balance sheet also reflected a $150,000            
          value for personal property.  Petitioners' household furnishings,           
          including furniture, silverware, and china, were all items which            
          Arlene received from her parents and grandparents (who were                 
          antique dealers), or which petitioners received as wedding                  
          presents.                                                                   
                                       OPINION                                        
               Section 6013(e)(1) provides:                                           
               (e) Spouse Relieved of Liability in Certain Cases.--                   
                    (1)  In general.  Under regulations prescribed by                 
               the Secretary, if--                                                    
                         (A)  a joint return has been made under                      
                    this section for a taxable year,                                  
                         (B)  on such return there is a                               
                    substantial understatement of tax                                 
                    attributable to grossly erroneous items of                        
                    one spouse,                                                       






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