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