Ronnie D. Wilson and Linda K. Lagadinos, f.k.a. Linda K. Wilson - Page 7

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          Thus, Linda has failed to establish that the deductions are                 
          grossly erroneous.  Accordingly, we conclude that Linda, pursuant           
          to section 6013(e), is not entitled to be relieved of tax                   
          liability with respect to the disallowed deductions.                        
               Respondent also determined that petitioners did not report             
          $22,715 of income from Ronnie's law practice.  Omissions from               
          gross income are grossly erroneous.  Sec. 6013(e)(2).  The                  
          understatement of tax attributable to the omitted income is                 
          substantial because it exceeds $500.  Sec. 6013(e)(3).  In                  
          addition, respondent has conceded that the omission is                      
          attributable to items of Ronnie.  Accordingly, with respect to              
          the omitted income, we conclude that Linda has established a                
          substantial understatement of tax attributable to grossly                   
          erroneous items of Ronnie.  We next determine whether Linda meets           
          the remaining requirements of section 6013(e).                              
          II.  Knowledge Requirement                                                  
               Linda must establish that in signing the return, she did not           
          know, and had no reason to know, of the substantial                         
          understatement of tax attributable to the omitted income from               
          Ronnie's law practice.  Sec. 6013(e)(1)(C).  More specifically,             
          she must establish that she did not know, or have reason to know,           
          about the income-producing transaction that Ronnie failed to                
          report.  Park v. Commissioner, supra at 1294; Bokum v.                      
          Commissioner, supra at 146.  A spouse seeking relief has reason             






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