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
deficiencies.
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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