- 39 - Over $1,500 of understatement-full scope Understatement of tax attributable to both spouses Erroneous items: Disallowed partnership losses on TP’s joint Schedule E RS’s attribution does not meet the attribution exceptions. This portion will be denied under IRC 6015(f). Continue IRC 6015(b) for the portion attributable to the NRS Knowledge factors: Background: RS-Education: Ph.D. in Physiology. NRS-Education: Doctorate Occupation: Research Scientist. of Science in Chemical Engineering. Occupation: Executive. Involvement: RS-RS states there was a joint NRS-NRS states he was checking account for household the primary bill matters and that the NRS had payer and that he other separate accounts. RS managed the account, states she used the joint balanced the check- account to write checks for book, reviewed the groceries, clothing for monthly bank state- herself and the children and ments and picked up household necessities. and opened the household mail. Lifestyle changes: None indicated. NRS’s elusiveness: No evidence of elusiveness or deceit. NRS states he gathered all information and sent it to the CPA. He states the preparation of the return had always been his responsibility. He states the RS did not ask questions that she trusted him and the CPA. Duty to inquire: RS states she did not review the return when signing. She states the NRS handles all financial matters and she trusted him and the CPA. She states she was busy raising three boys, managingPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
Last modified: May 25, 2011