Kathleen Patricia Peters - Page 16




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          Although finances and taxes may have been a contentious issue               
          between petitioner and Mr. Elesh, we find that petitioner                   
          voluntarily chose not to review the returns prior to signing                
          them.  We do not find credible petitioner’s testimony that she              
          was significantly pressured by the alleged threats by Mr. Elesh             
          to discontinue telephone or electrical service to his own home.             
          Petitioner testified that she “didn’t really have any reason to             
          worry” about the items on the tax returns, and that she “wasn’t             
          concerned about them, other than the fact that I know you’re                
          supposed to read something before you sign it.”  In the end,                
          petitioner simply was not sufficiently concerned with the tax               
          returns to review them or to question any items appearing                   
          thereon.                                                                    
               Because petitioner had full knowledge of the underlying                
          transaction, and failed to review or otherwise verify the                   
          accuracy of the returns prior to signing them, we do not find an            
          abuse of discretion in respondent’s denial of equitable relief to           
          petitioner.                                                                 
          Negligence Penalties                                                        
               Finally, we turn to the section 6662(a) accuracy-related               
          penalties.  This Court has held that:                                       
               it is an abuse of discretion to deny relief under section              
               6015(f) in an addition to tax or penalty situation when on             
               an individual basis the putative innocent spouse meets the             
               statutory standard generally applied to all taxpayers that             
               shows the addition to tax or penalty is inapplicable.                  






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