- 3 -
1981 $185,361 $55,608 ---
1982 27,232 8,170 1$6,808
1 Determined as alternative to sec. 6659 addition to tax.
Respondent also determined that interest on the entire
deficiencies for 1981 and 1982 is to be computed under section
6621(c).
After concessions,2 the issue for decision is whether
petitioner Nancy Silverman qualifies as an innocent spouse under
section 6013(e) with respect to the 1981 tax deficiency.
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and
the stipulated exhibits are incorporated herein by this
reference.
When the petition was filed in the instant case, petitioner
Nancy Silverman (hereinafter sometimes referred to as Nancy)
resided in Cincinnati, Ohio. The will of Sheldon Silverman
(hereinafter sometimes referred to as Sheldon) was admitted to
probate in the Surrogate's Court for Bergen County, New Jersey,
and that Court appointed Nancy as Executrix of Sheldon's estate.
Background
2 Respondent has conceded all the additions to tax.
Petitioners have conceded the deficiencies, the increased
interest under sec. 6621(c), and petitioner Nancy Silverman's
ineligibility for innocent spouse status for 1982.
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