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We so hold.6
Decisions will be entered
in accordance with respondent’s
Rule 155 computations.
6 The foregoing resolves the dispute as to both of the
claimed concessions. In addition, sec. 6653(b) provides that the
fraud addition to tax does not apply to a spouse on a joint tax
return unless some part of the underpayment is due to that
spouse’s fraud. Thus, a determination of one spouse’s fraud
liability may well be different from a determination as to the
other spouses’s fraud liability. E.g., Stone v. Commissioner, 56
T.C. 213, 226-228 (1971).
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