- 3 - negligence, and substantial understatement, for 1986 and 1987, if certain mathematical requirements were met under a Rule 155 computation. Sharer v. Commissioner, T.C. Memo. 1994-453. We directed that a decision in the case would be entered pursuant to Rule 155. Respondent subsequently agreed that petitioner (1) was not liable for an addition to tax for failure to file under section 6651(a) for 1986, because her withholding tax credits exceeded the amount of tax required to be shown on her return for 1986, (2) was not liable for an addition to tax for substantial understatement for 1986, because there was no substantial understatement of her income tax for that year, and (3) was liable, in recomputed amounts, for additions to tax for negligence under section 6653(a), for 1986 and 1987, and for an addition to tax for substantial understatement under section 6661 for 1987. Background Petitioner is an accountant. In 1975, she married Michael Sharer (Mr. Sharer). During their marriage, she and Mr. Sharer had one child, Derek, who was born in 1986. Their marriage was a stormy one. From early 1986 until Mr. Sharer's death in 1988, petitioner and Mr. Sharer did not live together but maintained separate households. However, they never filed for legal separation or divorce.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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