T.C. Memo. 2001-178
UNITED STATES TAX COURT
CHRISTA KARIN MUELLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3336-95. Filed July 19, 2001.
P and H filed a joint return for 1986. R
determined a deficiency in tax on account of omission
of embezzlement income and gain from liquidation of
corporation, both items attributable to H. R also
determined a sec. 6661, I.R.C., addition to tax for
substantial understatement of income. P challenges
deficiency and asks relief from liability under
sec. 6015, I.R.C., as a so-called innocent spouse.
1. Held: P and H omitted from income
embezzlement income and gain (in a reduced amount) of
H.
2. Held, further, P has failed to show error in
the determination of sec. 6661, I.R.C., addition to tax
for substantial understatement of income.
3. Held, further, P has failed to show
entitlement to relief from liability under sec. 6015,
I.R.C.
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