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Year Deficiency6653(b)(1)6653(b)(2)6653(b)(1)(A)6653(b)(1)(B)6661 6663
1985 $49,562 $ 24,781 1 --- --- $12,391 ---
1986 66,134 --- --- $99,125 2 33,042 ---
1987 97,352 --- --- $73,014 3 24,338 ---
1988 1,473 108,178 --- --- --- 36,059 ---
1989 21,904 --- --- --- --- --- $16,428
1990 3,300 --- --- --- --- --- 2,475
1 50% of the interest due on $49,562
2 50% of the interest due on $132,166
3 50% of the interest due on $97,352
After concessions, the issues for decision are:
(1) Whether petitioner is liable for additions to tax and
penalties for fraud under section 6653(b) or section 6663 for any
taxable year at issue. We hold that she is not.
(2) Whether petitioner qualifies for "innocent spouse"
relief under section 6013(e) for any taxable year at issue. We
hold that she does not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein. At the time the petition was filed in this
case, petitioner resided in Baton Rouge, Louisiana. During the
years at issue, petitioner was married to Wayne T. Goings (Mr.
Goings). Petitioner and Mr. Goings (occasionally the couple)
were divorced on March 19, 1993. The couple filed joint Federal
income tax returns for each taxable year at issue.
Petitioner is a high school graduate. She is also a
graduate of a secretarial school, having completed a 9-month
1(...continued)
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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