- 2 - 1. Held: W had reason to know of the understatement attributable to the disallowed deductions, and, therefore, W is not entitled to relief under sec. 6015(b)(1)(C), I.R.C. 2. Held, further, it would not be inequitable to hold W liable for the deficiencies in tax, and, therefore, W is not entitled to relief under sec. 6015(b)(1)(D), I.R.C. 3. Held, further, because W did not satisfy the eligibility requirements of sec. 6015(c)(3)(A)(i), I.R.C., prior to her death, H, as personal representative, is not entitled to elect relief under sec. 6015(c), I.R.C. 4. Held, further, under the facts and circumstances, R’s denial of equitable relief under sec. 6015(f), I.R.C., does not constitute an abuse of discretion. Declan J. O’Donnell, for petitioners. Randall L. Preheim, for respondent. HALPERN, Judge: By notice of deficiency dated April 14, 1987, respondent determined deficiencies in, and additions to, the Federal income tax liabilities of David C. and Barbara J. Jonson (separately, David or Barbara; together, the Jonsons), as follows:1 1 The petition in this case was filed on July 6, 1987, on behalf of six individuals, including David C. and Barbara J. Jonson. Pursuant to an order of this Court dated June 12, 1990, such individuals other than the Jonsons were severed as petitioners in this case, and the caption of this case was amended to read “David C. Jonson and Barbara J. Jonson, Petitioners v. Commissioner of Internal Revenue, Respondent”. Barbara died on Mar. 16, 1996, and, upon motion thereafter made by respondent, “Estate of Barbara J. Johnson, Deceased, David C. Jonson, Successor in Interest” was substituted for Barbara as a (continued...)Page: Previous 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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