- 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, 193-194Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011