Timothy R. Becherer - Page 7

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          whether the failure to report the correct tax liability on the              
          joint return results from concealment, overreaching, or any other           
          wrongdoing on the part of the other spouse.  Alt v. Commissioner,           
          supra at 314; Jonson v. Commissioner, 118 T.C. at 119.                      
               No such untoward circumstances are present in this case.               
          There was no concealment on Ms. Becherer’s part.  Ms. Becherer              
          never hid her employment from petitioner, and in fact petitioner            
          helped Ms. Becherer perform some of her employment duties.                  
          Petitioner had the opportunity to review the 1996 Federal income            
          tax return before it was filed.                                             
               A purpose of section 6015 relief “is to protect one spouse             
          from the overreaching or dishonesty of the other.” Purcell v.               
          Commissioner, 826 F.2d 470, 475 (6th Cir. 1987), affg. 86 T.C.              
          228 (1986).  The understatement of tax in this case is                      
          attributable to an omission of income from the employment                   
          activities of petitioner’s former spouse.  Petitioner had                   
          knowledge of Ms. Becherer’s employment activities.  Under these             
          circumstances, we perceive no inequity in holding petitioner and            
          Ms. Becherer to joint and several liability.  Bokum v.                      
          Commissioner, 992 F.2d 1132, 1135 (11th Cir. 1993), affg. 94 T.C.           
          126 (1990); McCoy v. Commissioner, 57 T.C. 732, 735 (1972).                 
               We conclude that holding petitioner liable for the                     
          deficiencies in tax for 1996 is not inequitable under section               








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