Stacy Lee Gonce - Page 6

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          offered therein.  Alt v. Commissioner, 119 T.C. 306, 313 (2002),            
          affd. 101 Fed. Appx. 34 (6th Cir. 2004).                                    
               Petitioner does not meet all the requirements of section               
          6015(b)(1) for 1999 or 2001.  The 1999 return does not include              
          the $2,829 of nonemployee compensation that petitioner received             
          from her newspaper route that year.  To the extent that the                 
          understatement of tax for 1999 is attributable to petitioner’s              
          own unreported income, it is not attributable solely to Mr. Gonce           
          as required for relief under section 6015(b)(1).                            
               Respondent concedes that the understatement of tax due for             
          2001 is attributable exclusively to Mr. Gonce.  However, section            
          6015(b)(1)(C) is not satisfied for either 1999 or 2001.                     
          Petitioner has not shown that she did not know and had no reason            
          to know of the understatement of tax in those years.  See                   
          Cheshire v. Commissioner, 115 T.C. 183, 192-193 (2000) (holding             
          that a requesting spouse does not meet the requirement of section           
          6015(b)(1)(C) if she has actual knowledge of the underlying                 
          transaction that produced the omitted income), affd. 282 F.3d 326           
          (5th Cir. 2002).  Petitioner had actual knowledge of the payments           
          she and Mr. Gonce received as compensation for maintaining their            
          individual newspaper routes during the years in issue.                      
          Petitioner had the opportunity to review the tax returns for                
          those years to ensure that all of petitioner’s and Mr. Gonce’s              
          income was reported accurately before she signed those returns,             

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