Philip H. Friedman and Anna Friedman - Page 10

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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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