- 3 - In September 1998, Sylvia and respondent entered into a stipulation resolving all issues with respect to Sylvia except Sylvia’s entitlement to relief from joint liability on the joint returns. The settlement stated: “Without considering the innocent spouse provisions of � 6013(e), there are deficiencies in income tax due from Ms. Johnson for the taxable years 1979 and 1980 in the amounts of $44,017 and $21,657, respectively.” The stipulation further provided that Sylvia was not liable for additions to tax under section 6653(a) for 1979 and 1980. It further provided: Without considering the innocent spouse provisions of I.R.C. � 6013(e), $44,017 and $21,657 of the deficiencies in tax due from Ms. Johnson for the taxable years 1979 and 1980, respectively, are substantial underpayments attributable to tax motivated transactions, for purposes of computing the interest payable with respect to such amounts, pursuant to I.R.C. � 6621(c). On July 22, 1998, the RRA was enacted. The statute, among other things, revised and expanded the relief from joint liability available to spouses filing joint returns. The relevant provisions of the RRA generally apply to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before that date and remaining unpaid on that date. On November 18, 1998, except for the provisions relating to relief from joint liability, an identical stipulation was filed in regard to the Hale Exemption Trust. On May 1, 2000, the Court filed a second stipulation ofPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011