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liability results in zero joint liability, then petitioner (the
innocent spouse) would be the recipient of a windfall in the form
of relief from the portion of the income tax liability
attributable to the short-term capital loss disallowance--relief
that was not intended by section 6013(e).
To reflect the foregoing,
Decision will be entered in
the amounts proposed in
respondent's computation.
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Last modified: May 25, 2011