Louise Coleman, Petitioner, Fred L. Nubin, Intervenor - Page 6

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          brought completed returns home for her to sign.  Because                    
          petitioner did nothing other than sign completed returns, it is             
          obvious that intervenor is the one who omitted substantial                  
          amounts of income when he prepared the returns.  There was no               
          evidence that petitioner had actual knowledge of the omitted                
          income.  Sec. 6015(c)(3)(C).  The record contains no reasons or             
          facts which showed error in respondent’s concession.                        
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decision will be                    
                                             entered for petitioner.                  
                                                                                     


























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