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.
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