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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 income
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