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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.
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