- 7 - former spouse. Sec. 6015(c) and (d); Culver v. Commissioner, 116 T.C. 189, 194 (2001). In the context of a disallowed deduction, “actual knowledge” under section 6015(c) requires proof that the spouse seeking relief had actual knowledge of the factual circumstances which made the item disallowable as a deduction. Mora v. Commissioner, 117 T.C. 279, 292 (2001); King v. Commissioner, 116 T.C. 198, 204 (2001). Isaac argues that the investments in the equipment leasing partnerships were allocable to Lora and himself and that Lora had actual knowledge of those investments. As a consequence, Isaac contends that Lora should not be entitled to relief under section 6015(c). Lora argues that the investments in the equipment leasing partnerships were allocable to Isaac and that she lacked actual knowledge of the underlying circumstances resulting in the disallowance of the deductions relating to these investments. Lora contends, and respondent has determined, that she meets the requirements for relief from joint liability under section 6015(c). We conclude that the equipment leasing partnership transactions are allocable to Isaac. Isaac made these investments in his name only. Isaac was a C.P.A. Isaac actively sought out the investments, and he marketed the investments to his own clients.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011