- 5 - available under either subsection. Washington v. Commissioner, 120 T.C. 137, 146-147 (2003); Hopkins v. Commissioner, 121 T.C. 73, 88 (2003); Block v. Commissioner, supra. In this case, there is a deficiency in tax; consequently, petitioner can be considered for relief under section 6015(b) as well as section 6015(c) or (f). Under section 6015(b), a taxpayer is entitled to full or apportioned relief from joint and several liability for an understatement of tax on a joint return if, among other requirements, the taxpayer establishes that he or she “did not know, and had no reason to know” that the other spouse understated the tax on the return. Sec. 6015(b)(1)(C). In this case, the adjustments in the notice of deficiency all related to the self-employed business activity of Mr. Elias as an agent for State Farm and, more specifically, the disallowance of certain deductions claimed on the return relating to that activity. Essentially, the disallowed items included expenses for travel, meals, and entertainment. Respondent determined, upon examination of receipts provided by petitioner, that the disallowed expenses included meals petitioner had consumed, trips that she took, and gasoline, all of which respondent determined were personal expenses that were unrelated to Mr. Elias’s insurance agency activity. Some of the expenses were for family trips to Disneyland (a popular resort located in California) andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011