- 2 - Bruce I. Hochman and Michel R. Stein, for petitioner Margaret Ann Carpender. Steven M. Roth, for respondent. SUPPLEMENTAL MEMORANDUM OPINION NIMS, Judge: Margaret Ann Carpender (petitioner) moves the Court for reconsideration of its memorandum opinion at T.C. Memo. 1998-3. See Rule 161. Unless otherwise stated, section references are to sections of the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. In Wiksell v. Commissioner, T.C. Memo. 1998-3, we reevaluated our prior decision in Wiksell v. Commissioner, T.C. Memo. 1994-99, as directed by the Ninth Circuit on remand in Wiksell v. Commissioner, 90 F.3d 1459 (9th Cir. 1996). We held that petitioner was entitled to innocent spouse relief under section 6013(e) for deficiencies in excess of the amounts relating to checks she received from her husband's company, Hitech, and that it would not be inequitable to hold petitioner liable for deficiencies related to the Hitech checks. Wiksell v. Commissioner, T.C. Memo. 1998-3. In her motion to reconsider our decision in Wiksell v. Commissioner, T.C. Memo. 1998-3, petitioner argues that section 6015(c)(3)(C), enacted by section 3201(a) of the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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