- 7 - 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 sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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