Theron R. Livingston, Sr. - Page 1

                                  T.C. Memo. 2000-121                                   

                                UNITED STATES TAX COURT                                 

                       THERON R. LIVINGSTON, SR., Petitioner v.                         
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                       

                         MICHELE D. LIVINGSTON, Petitioner v.                           
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket Nos. 8691-97, 15040-97.           Filed April 6, 2000.            

                    H pleaded guilty to criminal tax evasion for taxable                
               year 1990, admitting to a specified amount of unreported                 
               income as determined through R’s reconstruction of H’s 1990              
               income by the net worth method in the criminal proceeding.               
               Subsequently, for purposes of establishing H’s civil tax                 
               liability for taxable years 1989 and 1990, R determined H’s              
               unreported income by relying directly on the criminal net                
               worth summary.  R’s 1989 net worth computation assumed that              
               H had a zero opening net worth and was based on inconsistent             
               inclusions of H’s and W’s incomes, assets, and expenditures.             
                    For taxable year 1990, H and W filed a joint Federal                
               income tax return.  In her original petition, W sought                   
               innocent spouse relief under former sec. 6013(e), I.R.C.                 
               After the trial in this case, former sec. 6013(e), I.R.C.                

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011