Ronnie D. Wilson and Linda K. Lagadinos, f.k.a. Linda K. Wilson - Page 5

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                                       OPINION                                        
               A husband and wife who file a joint return generally are               
          jointly and severally liable for the tax due.  Sec. 6013(d)(3).             
          A taxpayer will be relieved of liability as an innocent spouse,             
          however, to the extent the taxpayer establishes that:  (1) A                
          joint Federal income tax return was filed; (2) on the return                
          there is a substantial understatement of tax attributable to                
          grossly erroneous items of the other spouse; (3) in signing the             
          return, the taxpayer did not know, and had no reason to know, of            
          the substantial understatement; and (4) taking into account all             
          of the facts and circumstances, it would be inequitable to hold             
          the taxpayer liable for the deficiency attributable to the                  
          substantial understatement.  Sec. 6013(e)(1).  Linda bears the              
          burden of proving that she satisfies each of the four                       
          requirements.  Rule 142(a); Flynn v. Commissioner, 93 T.C. 355,             
          359 (1989).  Her failure to satisfy any one of the requirements             
          will preclude relief from liability.  Park v. Commissioner, 25              
          F.3d 1289, 1292 (5th Cir. 1994), affg. T.C. Memo. 1993-252; Bokum           
          v. Commissioner, 94 T.C. 126, 138 (1990), affd. 992 F.2d 1132               
          (11th Cir. 1993).                                                           
               Respondent concedes that a joint return was filed for the              
          1989 tax year.  She contends, however, that Linda does not meet             
          the remaining requirements.  We discuss these requirements in               
          turn.                                                                       






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