Eloise Gaddy Joens - Page 2

                                                 - 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

Last modified: May 25, 2011