- 7 - did not read or review the return, nor did she ask any questions pertaining to it prior to affixing her signature. She claimed no knowledge of financial affairs and tax matters. Mrs. Meyer acknowledged that if she had questioned her husband regarding the return he would have answered her truthfully. On June 23, 1994 respondent timely mailed a statutory notice of deficiency to petitioner and her husband in which a deficiency was determined for 1989 in the amount of $59,718 in income tax and additions to tax of $3,076 and $4,182 pursuant to sections 6651(a)(1) and 6654(a), respectively, and a penalty of $11,944 pursuant to section 6662. Respondent derived the income tax deficiency from: (1) The omission from income of a $180,748 constructive dividend from AED; (2) disallowed Schedule C expenses in the amount of $19,753; (3) a reduction of $20 to Schedule C income reported; and (4) an increase of $161 for omitted interest income from petitioner's personal accounts at Norstar and Dollar Dry Dock banks. Petitioner conceded the correctness of the amounts of all items in the deficiency, asserting only that she qualified for innocent spouse relief. Petitioner does not argue or attempt to prove that the omitted income adjustment of $161 or the adjustment in favor of the petitioner of $20 for overstated Schedule C gross receipts set forth in the statutory notice of deficiency qualifies for innocent spouse relief. Accordingly, petitioner has not met her burden of proof with respect to these adjustments. Rule 142(a).Page: 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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