- 3 -
related tax deficiency", the case would be remanded to this Court
to "determine what portion, if any, of the deficiency is subject
to innocent spouse relief." Wiksell v. Commissioner, supra at
1464.
By Order dated April 15, 1997, we granted petitioner's
Motion to Change Caption. The amended caption of this case
reflects the fact that Margaret's name was legally changed after
her divorce from David. A further trial was held in the remanded
matter.
The sole issue for decision is whether petitioner qualifies
for innocent spouse relief pursuant to section 6013(e) with
respect to any portion of the deficiencies asserted in
respondent's amended answer for taxable years 1984 and 1985.
Petitioner resided in Newhall, California, when the petition
was filed.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and attached exhibits are incorporated
herein by this reference. We adopt in full the findings of fact
in our prior memorandum opinion. For convenience, we shall
repeat the facts as necessary to clarify the ensuing discussion,
and we make additional findings of fact.
David and Margaret were married in 1960, legally separated
in 1988, and divorced in December, 1992. They had three
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