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on hand balance, is without merit. The parties stipulated the
correctness of all aspects of the net worth method other than the
ending cash on hand balance on December 31, 1989. Petitioners'
contention that a cash hoard existed at the beginning of 1989 is
inconsistent with the stipulation of a zero cash on hand balance at
the end of 1988 and with petitioners' argument that safe deposit
box 3567 did not belong to Mr. Zaban.
Accordingly, we sustain respondent's determination of $115,100
as the ending cash on hand balance for the 1989 net worth
calculation.
Issue 2. Innocent Spouse
The second issue for decision is whether Mrs. Zaban is
entitled to innocent spouse relief. Mrs. Zaban asserts that she is
entitled to such relief for 1986 through 1990. Respondent argues
that Mrs. Zaban fails to meet three of the four statutory elements
for relief.
Spouses who file a joint income tax return generally are
jointly and severally liable for its accuracy and the tax due,
including any additional taxes, interest, or penalties determined
on audit of the return. Sec. 6013(d)(3). However, pursuant to
section 6013(e), a spouse (commonly referred to as an innocent
spouse) can be relieved of tax liability if that spouse proves: (1)
A joint income tax return was filed; (2) the return contained a
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