- 2 - All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. All dollar amounts are rounded to the nearest dollar. After concessions, the issues for decision are: (1) Whether petitioner qualifies as an innocent spouse under section 6013(e) for 1982, 1983, and 1984. We hold she does not. (2) Whether petitioner is liable for additions to tax for fraud under section 6653(b) for 1982, 1983, and 1984. We hold she is. (3) Whether petitioner is liable for additions to tax for substantial understatement for 1982, 1983, and 1984. We hold she is. Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits are incorporated into our findings by this reference. At the time the petition in this case was filed, petitioner resided in Boynton Beach, Florida.1 General Background Petitioner married Nelson Emmens (Emmens) in 1981. Petitioner and Emmens filed joint returns for 1982, 1983, and 1984, reporting adjusted gross income of ($5,803), $17,956, and $24,759, respectively, and total taxes of $231, $1,690, and $2,857, respectively. 1 At the time of trial, petitioner had remarried and was a resident of Urbandale, Iowa.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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