Patricia M. Mora, F.K.A. Patricia Rasberry - Page 1

                                   117 T.C. No. 23                                    

                               UNITED STATES TAX COURT                                

                    PATRICIA M. MORA, F.K.A. PATRICIA RASBERRY,                       
                                   Petitioner, AND                                    
                          LYNN RASBERRY, Intervenor v.                                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6154-00.                 Filed December 17, 2001.           

                    H invested in a tax shelter limited partnership                   
               that passed through substantial losses that were                       
               claimed on the joint Federal income tax returns H and W                
               filed for the taxable years 1985 and 1986, and                         
               disallowed by R.  After H and W were divorced W sought                 
               relief from joint and several liability.  R denied W’s                 
               request for relief from joint and several liability                    
               under sec. 6015(b) and (c), I.R.C., on the ground that                 
               W had knowledge of the items giving rise to the                        
                    Held, W is not entitled to relief from joint and                  
               several liability under sec. 6015(b), I.R.C.; W had                    
               reason to know of the understatements by reason of the                 
               size of the losses in relation to the income of H and                  
               W.  A reasonable person in W’s position would have made                
               inquiries to determine the legitimacy of the losses,                   
               and W failed to make any such inquiries.                               

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