Fatemeh Entezam - Page 4

                                        - 4 -                                         
               Ms. Entezam and Mr. Zahedi were divorced in 1999.  The                 
          divorce judgment provides that Ms. Entezam and Mr. Zahedi are               
          each responsible for the payment of half of their Federal income            
          tax liabilities relating to 1990, 1991, and 1992.                           
               By notice of deficiency dated June 1, 2000, respondent                 
          determined that Ms. Entezam and Mr. Zahedi underreported gross              
          receipts of $64,915, $157,035, $148,717, and $154,940 on their              
          1989, 1990, 1991, and 1992 joint Federal income tax returns,                
          respectively.                                                               
               On September 1, 2000, Ms. Entezam, while residing in                   
          Escondido, California, filed a petition in which she requested              
          relief from joint and several liability.  On January 11, 2001,              
          Mr. Zahedi, while residing in Lake Forest, California, filed his            
          notice of intervention.  On July 12, 2001, an Internal Revenue              
          Service Appeals officer determined, pursuant to section 6015(f),            
          that Ms. Entezam did not qualify for relief.                                
                                       OPINION                                        
               In limited situations, taxpayers filing joint Federal income           
          tax returns may be relieved from joint and several liability                
          pursuant to section 6015.  Ms. Entezam, however, is not entitled            
          to such relief.  Her actual knowledge of the tax understatement             
          precludes relief pursuant to section 6015(b) or (c).  Sec.                  
          6015(b)(1)(C) and (c)(3)(C); Jonson v. Commissioner, 118 T.C.               
          106, 115 (2002); Cheshire v. Commissioner, 115 T.C. 183, 193-194            






Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011