- 12 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
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