- 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, managing
Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 NextLast modified: May 25, 2011