Anna Ruth French - Page 8

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          substantial understatement.  Sec. 6013(e)(1), as amended by the             
          Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 424(a), 98              
          Stat. 801-802; Purcell v. Commissioner, 86 T.C. 228, 235 (1986),            
          affd. 826 F.2d 470 (6th Cir. 1987).  Petitioner bears the burden            
          of establishing that each of the four requirements of section               
          6013(e) has been satisfied.  Purcell v. Commissioner, 826 F.2d at           
          473; Sonnenborn v. Commissioner, 57 T.C. 373, 381-383 (1971).               
               The requirements of section 6013(e) are conjunctive rather             
          than alternative; a failure to meet any of the requirements                 
          prevents a spouse from qualifying for relief under section                  
          6013(e).  Cohen v. Commissioner, T.C. Memo. 1987-537; Estate of             
          Killian v. Commissioner, T.C. Memo. 1987-365; Levin v.                      
          Commissioner, T.C. Memo. 1987-67.  The parties agree that                   
          petitioner and Mr. French filed a joint return for the taxable              
          year in issue.  The parties also agree, and we find, that there             
          is a substantial understatement of tax attributable to a grossly            
          erroneous item of Mr. French’s for the taxable year in issue.               
          Whether petitioner fulfilled the remaining requirements of                  
          section 6013(e), however, is disputed.                                      
               Section 6013(e)(1)(D)--Inequitable                                     
               Petitioner must prove that, given the facts and                        
          circumstances, it would be inequitable to hold her liable for the           
          deficiency attributable to Mr. French’s substantial                         
          understatement.  Sec. 6013(e)(1)(D); sec. 1.6013-5(b), Income Tax           
          Regs.  Section 6013(e), as amended, no longer requires us to                

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