Andrew J. Zoglman - Page 9

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          F.2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228).                 
          Normal support is not considered a significant benefit.  Hayman             
          v. Commissioner, supra at 1262 (citing Flynn v. Commissioner, 93            
          T.C. 355, 367 (1989)).                                                      
               Petitioner received significant benefits as a result of                
          filing a joint return on which the Social Security benefits went            
          unreported.  The joint return filed by the parties reflected                
          taxable income derived almost exclusively from petitioner.                  
          Filing a joint return with Ms. Morrison allowed petitioner to               
          significantly reduce his taxable income using exemptions and                
          itemized deductions attributable to Ms. Morrison, her mother, and           
          her daughter.  Had he not filed the joint return with Ms.                   
          Morrison, petitioner’s tax liability would have been                        
          substantially higher.  Further, had Ms. Morrison filed a separate           
          return properly including her benefits, she would have had                  
          little, if any tax liability.  Her tax liability arose when her             
          benefit income was added to petitioner’s income on the joint                
          return.                                                                     
               The parties’ failure to report the correct tax liability was           
          not the result of concealment, overreaching, or any other                   
          wrongdoing on the part of Ms. Morrison.  Ms. Morrison was                   
          forthright and never made any attempt to conceal from petitioner            
          the amount of benefits she received.  She presented her benefit             
          statement to the return preparer while in the presence of                   






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