Andrew J. Zoglman - Page 5

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          and the joint filing status was allowed, permitting petitioner              
          the benefit of exemptions, itemized deductions for medical                  
          expenses (reflected on the adjusted joint return totaling                   
          $9,486), and expenses attributable to Ms. Morrison, her mother,             
          and her daughter.  In addition, petitioner obtained the benefit             
          of itemized deductions relating to mortgage interest and real               
          estate taxes on the joint return of $11,734 and $2,632,                     
          respectively.  As a result of the initial audit, petitioner and             
          Ms. Morrison were issued a refund of $415.  After discovery of              
          $28,146 of unreported Social Security income, respondent, during            
          1999, audited the 1996 joint return a second time.  Respondent              
          determined a $3,347 deficiency based on the unreported Social               
          Security income.  The corresponding increase to adjusted gross              
          income resulted in purely mathematical reductions in itemized               
          deductions, in the amount of $2,674.                                        
                                       OPINION                                        
               The issue we consider is whether petitioner is eligible for            
          relief from joint and several liability under subsections (b) or            
          (c) of section 6015.                                                        
          I.  Relief Under Section 6015(b)(1)                                         
               Section 6015(b)(1) provides for spousal relief from joint              
          and several liability if the following requirements are met:                
                    (A) a joint return has been made for a taxable                    
               year;                                                                  
                    (B) on such return there is an understatement of                  





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