- 17 - understatement of tax or that further investigation was warranted. Petitioner has satisfied the section 6015(b)(1)(C) requirement. The final question is whether, taking into account all the facts and circumstances, it would be inequitable to hold petitioner liable for the deficiency attributable to the understatement on the joint 1983 tax return. Sec. 6015(b)(1)(D). Respondent argues that it would not be inequitable for petitioner to be held liable for the understatement on the joint 1983 tax return because title to the remaining condominiums was transferred in 1997 to her name alone. The Hendrickses acquired the condominiums before Mr. Hendricks invested in Boulder Oil and Gas. The condominiums were acquired by exchanging other property the Hendrickses had previously owned and were not acquired from proceeds made available through the investment in Boulder Oil and Gas. Mr. Hendricks transferred his joint interest in the remaining condominiums to petitioner nearly 3 years before respondent assessed the deficiency for 1983 and began collection action against the Hendrickses for that tax year. The Hendrickses had paid the balances due for 1980-82 with moneys, derived in part, from the sale of several of the condominiums, and the Hendrickses mistakenly believed that they had settled the 1983 tax year and did not owe any more tax liabilities.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011