the relevant taxable years, and all Rule references are to the Tax Court Rules of Practice and Procedure. The parties submitted memoranda and affidavits in support of their positions. Neither party requested a hearing. We decide the motion based on the pleadings, petitioners' motion for litigation costs, respondent's objection to that motion, the supporting memoranda and affidavits, and the record in these cases. The primary issues in the underlying opinion, Gaskins v. Commissioner, T.C. Memo. 1995-511, filed October 26, 1995, were whether petitioner Elaine Gaskins and petitioner Sabina A. Quinn were entitled to relief as innocent spouses under section 6013(e). We held that both petitioner wives were entitled to such relief. However, the path to that result was long and winding, with unnecessary obstacles and delays along the way. Background On February 8, 1991, respondent mailed notices of deficiency to petitioners William C. and Elaine Gaskins (the Gaskins) and Pasquale T. and Sabina A. Quinn (the Quinns), determining deficiencies in income tax for the taxable years 1979, 1980, and 1981, and determining, against petitioner husbands, additions to tax for fraud for those years. On May 6, 1991, the Gaskins and the Quinns, through their attorney, James J. Riley (Attorney Riley), filed their respective petitions with this Court. Those petitions assigned as errors the determination of unreportedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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