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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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