- 26 -                                         
          Commissioner, supra at 1504; Purcell v. Commissioner, supra at              
          473.                                                                        
               The parties agree that a joint return was filed.  The record           
          also compels the conclusion that the understatement of $55,263              
          attributable to the items in question was substantial, sec.                 
          6013(e)(3), and we so find.                                                 
               Respondent has contested each of the remaining issues,                 
          including whether the deficiency exceeds the specified percentage           
          of petitioner’s adjusted gross income for 1983, her preadjustment           
          year.  Sec. 6013(e)(4)(C).  Section 6013(e)(4)(A) requires that             
          the substantial understatement exceed 10 percent of the claimant            
          spouse’s adjusted gross income (AGI) for the preadjustment year             
          if the AGI is $20,000 or less.  We find that petitioner’s                   
          adjusted gross income for 1983 could not have exceeded $6,835               
          even if additional items of income described in the record, which           
          may well have been reported in other taxable years, are added to            
          petitioner’s reported 1983 adjusted gross income.  The                      
          understatement of $55,263 exceeds 10 percent of petitioner’s 1983           
          adjusted gross income.                                                      
               We consider each of the remaining contested elements.                  
          1.   “Grossly Erroneous Items of One Spouse”                                
               a.  Attributable to Other Spouse                                       
               Respondent does not argue that the disallowed Stonehurst               
          deductions claimed on the 1979 return were not attributable to              
          Mr. Heitzman.  The record shows that petitioner had no ownership            
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