Helen M. Korchak - Page 39

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               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                          





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