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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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