David C. Jonson and Estate of Barbara J. Jonson, Deceased - Page 2

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                    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                  

               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            

               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             

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