121 T.C. No. 5
UNITED STATES TAX COURT
MARIANNE HOPKINS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 363-01. Filed July 29, 2003.
P and H filed joint returns for 1982, 1983, 1984,
1988, and 1989. Adjustments to partnership deductions
and NOL deductions resulted in tax deficiencies for
1982, 1983, and 1984. The partnership deductions are
attributable to H’s partnership. The NOL deductions
are attributable to P’s property. P and H reported
taxes due on their joint returns for 1988 and 1989;
however, they failed to pay those amounts. After P and
H were separated, P filed a request for relief under
sec. 6015, I.R.C., with respect to her joint and
several tax liabilities for 1982, 1983, 1984, 1988, and
1989.
Held: P is not entitled to relief under sec.
6015(b), I.R.C., for 1982, 1983, and 1984 because the
NOL deductions are P’s tax items and because she has
not established that in signing the returns she had no
reason to know that there were understatements
attributable to H’s partnership deductions.
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