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6015(b), (c), and (d); Hopkins v. Commissioner, 121 T.C. ___
(2003).
B. Disallowed Schedule A Deductions of $4,841
Respondent also increased petitioners’ income by $4,841
(associated with the disallowance of some of Mr. Weiler’s
unreimbursed employee expenses) (the $4,841 adjustment). The
$4,841 adjustment is attributable and allocable to Mr. Weiler.
Respondent concedes, and we agree, that Ms. Weiler is relieved
from liability for tax (including alternative minimum tax) and
penalties attributable or allocable to the $4,841 adjustment.
Sec. 6015(b) and (c).
Respondent’s concession, again, does not address whether Ms.
Weiler is relieved from the interest attributable or allocable to
the $4,841 adjustment. For the reasons stated supra, we conclude
that Ms. Weiler is relieved from liability for the interest
attributable to the $4,841 adjustment.
Mr. Weiler seeks to be relieved from the penalties and
interest associated with the $4,841 adjustment.7 We conclude
6(...continued)
business that produced the $14,065 adjustment was Ms. Weiler’s.
Accordingly, the income associated with this business is
allocable to her.
7 Mr. Weiler concedes that he owes the money associated
with the disallowance of some of his unreimbursed employee
expenses. We construe this concession to mean that Mr. Weiler
agrees that he is liable for the taxes attributable or allocable
to the $4,841 adjustment. We note that the exception contained
(continued...)
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