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Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653 (a)(1)(A) 6653(a)(1)(B)
1986 $2,707,872 $269,713 $135,394 1
1987 1,725,692 426,884 86,285 1
1 50 percent of the interest due on the deficiency.
All section references are to the Internal Revenue Code in
effect for the years under consideration, and all Rule references
are to the Tax Court’s Rules of Practice and Procedure, unless
otherwise indicated.
The sole issue for consideration is whether petitioner
should be relieved of liability for any portion of the income tax
and additions to tax under the provisions of section 6015.
Entitlement to relief is, in part, dependent upon a taxpayer’s
knowledge about the questioned item(s) at the time of signing a
joint return.
FINDINGS OF FACT
Petitioner and her husband, Glen H. Martin, filed delinquent
joint Federal income tax returns on December 31, 1987, and April
4, 1989, for their 1986 and 1987 tax years, respectively. At the
time of the filing of her petition, petitioner’s legal residence
was Dallas, Texas. Petitioner’s husband has been incarcerated in
a Federal penitentiary since 1995.
Petitioner was born in 1935 in Canada and was one of six
children. She discontinued her education at age 14 and entered
into a training program with the Royal Bank of Canada. She
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