Thomas Corson and Judith Corson - Page 3




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          3201, 112 Stat. 685, 734, confer upon the spouse not seeking                
          relief from joint and several liability rights that make such a             
          denial appropriate.                                                         
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the relevant            
          years, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                     Background                                       
               Thomas and Judith Corson filed a joint Federal income tax              
          return for their 1981 taxable year.  (For convenience, Thomas               
          Corson and Judith Corson will hereinafter be referred to                    
          collectively as petitioners and individually as Thomas and                  
          Judith, respectively.)  Petitioners subsequently separated in               
          1983 and divorced in 1984.  A joint notice of deficiency was                
          issued by respondent to petitioners on April 12, 1985,                      
          determining a tax deficiency of $21,711 and additions to tax                
          pursuant to section 6653(a)(1) and (2).  Respondent further                 
          determined that the deficiency constituted a substantial                    
          underpayment attributable to tax motivated transactions, thus               
          rendering applicable the provisions for increased interest under            
          section 6621(d).  The $21,711 deficiency resulted largely from              
          disallowance of losses relating to petitioners’ investments in              
          one of a group of tax shelter limited partnerships.  In July of             








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