- 2 - was repealed and replaced by sec. 6015, I.R.C. Subsequently, W filed administrative elections for relief pursuant to sec. 6015(b) and (c), I.R.C. R made a full concession of W’s liability under sec. 6015(c), I.R.C., but made no determination under sec. 6015(b), I.R.C. W seeks judicial determination of her entitlement to relief under sec. 6015(b), I.R.C. 1. Held: for taxable year 1989, respondent’s determination of H’s unreported income through use of the net worth method is not sustained. 2. Held: for taxable year 1990, respondent’s determination of H’s unreported income through use of the net worth method is modified. 3. Held: for taxable year 1990, respondent having fully conceded W’s tax liability pursuant to her election under sec. 6015(c), I.R.C., the question of her entitlement to relief under sec. 6015(b), I.R.C. is moot. Ramsey R. Taylor and G. Norris Watson, for petitioner in docket No. 8691-97. Howard B. Teller, for petitioner in docket No. 15040-97. Richard A. Stone, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: In these consolidated cases, respondent determined deficiencies, additions to tax, and an accuracy- related penalty in petitioners’ Federal income taxes as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011