Terri L. Steffen - Page 11




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          reference to “tax” included additions to tax, additional amounts,           
          and penalties.  Sec. 6662(a)(2).  Thus, the additions to tax for            
          negligence in this case apply jointly and severally because a               
          joint return was filed.9  Pesch v. Commissioner, 78 T.C. 100,               
          128-129 (1982); Davenport v. Commissioner, 48 T.C. 921, 926                 
          (1967); Fleming v. Commissioner, T.C. Memo. 1989-10.                        
               Petitioner and Mr. Bilzerian filed a joint return for the              
          taxable year 1986.  Under these circumstances, a determination              
          that one spouse is liable for additions to tax results in the               
          other spouse’s also being liable therefor.  Estate of Sperling v.           
          Commissioner, T.C. Memo. 1963-260, affd. 341 F.2d 201 (2d Cir.              
          1965); see also Dillin v. Commissioner, 56 T.C. 228, 248  (1971).           
          Accordingly, we hold that petitioner is liable for the additions            
          to tax for negligence for 1986.                                             

                                                  Decision will be entered            
                                             under Rule 155.                          











               9Petitioner has not raised entitlement to relief from joint            
          liability under either sec. 6013 or sec. 6015, which replaced               
          sec. 6013.                                                                  





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