- 28 - section 6015 with respect to an underpayment of tax for her taxable year 1982. Petitioner is seeking relief under section 6015 with respect to an understatement of tax for that year. In Part 3 of petitioner's Form 12510, petitioner provided the responses indicated to the following questions with respect to petitioner’s knowledge of any items that caused the under- statement: 1a. At the time of signing, were you concerned about any item(s) omitted from or reported on the return(s) 9 Yes : No * * * * * * * 1c. At that time, describe how much you knew about each of the incorrect item(s) I did not know anything at all about the corrected item, Madison Recycling, LLC. As previously stated, I knew the return was prepared by our accountant, a CPA, and by my husband of then 23 years. I signed the return when asked because I trusted my husband completely. I believed that since it had been reviewed and prepared by a CPA and my husband, that everything was correct. 2. At the time of signing, if you were not concerned about any item(s), when and how did your first become aware of the incorrect item(s) In 1988, the IRS sent a notice to us with a large proposed 1982 tax liability because it intended to disallow a deduction related to Madison Recycling. I never knew about my husband’s investment in Madison Recycling and the tax deduction until then when he informed me for the first time. Part 4 of Form 12510 listed, inter alia, various income items and various expense items. For example, the various incomePage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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