Mary Lee Sharer - Page 3

                                           - 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

Last modified: May 25, 2011