MEMORANDUM FINDINGS OF FACT AND OPINION NIMS, Judge: Respondent determined a deficiency in petitioner's Federal income tax for 1989 of $59,718. Respondent also determined the following: (1) an addition to tax of $3,076 under section 6651(a)(1); (2) an accuracy-related penalty of $11,944 under section 6662 due to a substantial understatement of income tax, and (3) an addition to tax of $4,182 under section 6654(a) as a result of the failure of petitioner to pay estimated income tax. After concessions, the sole remaining issue for decision is whether Rosemarie Meyer (petitioner or Mrs. Meyer) may claim innocent spouse status under section 6013(e) for 1989. For the reasons that follow, we hold that petitioner does not qualify for such relief. All section references, unless otherwise specified, are to sections of the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The parties have stipulated to some of the facts and the Court has so found. This reference incorporates the stipulation of facts and attached exhibits. Mrs. Meyer resided in Lindenhurst, New York, when she filed her petition. FINDINGS OF FACT Petitioner wed Robert J. Meyer in 1967 and remained married to him at the time of trial, although the couple separated inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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