Fatemeh Entezam - Page 5

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          (2000), affd. 282 F.3d 326 (5th Cir. 2002).  Ms. Entezam, who has           
          a business degree, knew that large amounts of income were omitted           
          from the 1989 through 1992 joint tax returns.  Her contentions to           
          the contrary were not credible.  Ms. Entezam and members of her             
          family were involved in the operation of and record keeping                 
          relating to the business.  In addition, she signed two mortgage             
          loan applications reporting business income that significantly              
          exceeded the business income reported on the joint tax returns.             
          Moreover, she acknowledged that she willfully filed false joint             
          tax returns relating to 1989 through 1992.                                  
               Similarly, Ms. Entezam is not entitled to relief, pursuant             
          to section 6015(f), because it is not inequitable to hold her               
          liable for the deficiencies attributable to the unreported gross            
          receipts.  See Butler v. Commissioner, 114 T.C. 276, 291-293                
          (2000).  Ms. Entezam knew of the unreported gross receipts, did             
          not establish that she would suffer economic hardship if relief             
          were denied, significantly benefited from the unreported gross              
          receipts (i.e., funds deposited into a joint account afforded her           
          a very comfortable lifestyle), and has a legal obligation                   
          pursuant to a divorce judgment to pay for half of the tax                   
          liability.  See Rev. Proc. 2000-15, 2000-1 C.B. 447.  Thus,                 
          respondent’s determinations are sustained.                                  
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  






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