Robert H. and Judith A. Golden - Page 5




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          facts and circumstances, it is inequitable to hold the requesting           
          spouse liable for the deficiency in tax for the taxable year                
          attributable to the understatement.  The requesting spouse’s                
          failure to meet any one of these requirements prevents him or her           
          from qualifying for full or apportioned relief under section                
          6015(b).  Alt v. Commissioner, supra at 313.                                
               Petitioner does not meet the second, third, or fourth                  
          requirement for full or apportioned relief under section 6015(b).           
          The erroneous items, the losses from the partnership, are not               
          attributable solely to Golden.  Petitioner admits that the                  
          investment in the partnership was explained to her and that she             
          was aware of her status as a limited partner.  She further admits           
          that she received the annual reports from the partnership listing           
          her losses, that Golden truthfully discussed the partnership with           
          her regularly, and that she willingly signed the tax returns for            
          the subject years without reviewing them.  As to the latter                 
          point, a reasonably prudent person in the position of petitioner,           
          a college-educated individual, would have reviewed each return              
          and at least inquired about the losses reported each year.  As              
          this Court has previously stated in similar settings, a spouse              
          cannot escape tax responsibilities by ignoring the contents of a            
          tax return when signing it.  See Mora v. Commissioner, 117 T.C.             
          279, 289 (2001); Albin v. Commissioner, T.C. Memo. 2004-230; see            
          also Levin v. Commissioner, T.C. Memo. 1987-7.  Given that                  







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