Estate of Edward Wenner - Page 2




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                                       OPINION                                        

               LARO,  Judge: Petitioners petitioned the Court to review               
          respondent’s determination not to abate interest pursuant to                
          section 6404.1  Petitioner Dallas Clark also alleges in the                 
          petition that she should be relieved from joint liability as to             
          Federal income tax returns which she filed with her now deceased            
          husband for the relevant years.  We must decide whether the Court           
          has jurisdiction to decide Ms. Clark’s claim as to joint                    
          liability.  We hold that we have jurisdiction.                              
                                     Background                                       
               Edward Wenner died in 1988.  On or about March 1990 Kate               
          Wenner Eisner, acting for the estate, and Ms. Clark executed a              
          Form 870-P, Agreement to Assessment and Collection of Deficiency            
          in Tax for Partnership Adjustments.  On September 29, 1997,                 
          respondent sent to Edward (then deceased) and Dorothy Wenner                
          (now Ms. Clark) notices of changes to their 1982, 1983, and 1984            
          joint Federal income tax returns.  Those changes resulted from an           
          examination of those returns and the related partnership returns.           
          Respondent increased the amount of tax for each of the years and            
          claimed interest in the following amounts:                                  





               1Unless otherwise indicated, section references are to the             
          Internal Revenue Code in effect for the years in issue.                     




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