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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.
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