- 16 - Commissioner, 77 T.C. 582, 598 (1981). The Chens did not do this and so cannot offset their 1998 gross income with a business bad debt deduction. Conclusion We reject each of the Chens’ arguments. Because of the fraud involved, the IRS has no time limit for assessing the unpaid tax, so the statute of limitations had not passed. Unreported income of $272,963 was omitted from the Chens’ 1998 return. The Chens are liable for the fraud penalty due to their intentional failure to report the insurance proceeds. And finally, Mrs. Chen does not qualify for innocent spouse relief. To reflect the Commissioner’s concession, however, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011