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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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