- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011