Victoria Rae Moore - Page 3

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               By means of an October 2, 1996, determination, respondent              
          disallowed the Moores’ claimed partnership losses and determined            
          income tax deficiencies, additions to tax, and penalties for the            
          taxable years 1992, 1993, and 1994.  By means of an October 30,             
          2002, determination, respondent disallowed the Moores’ claimed              
          partnership losses for 1997 and determined an income tax                    
          deficiency and penalties for that year.  The Moores carried back            
          some of those losses to their 1987 through 1991 tax years.                  
               On December 23, 1996, the Moores petitioned the Tax Court              
          seeking review of respondent’s October 2, 1996, determination.              
          That case was assigned docket No. 27274-96.  Among other                    
          allegations, the Moores contended in docket No. 27274-96 that the           
          3-year period for assessment had expired, but no claim for relief           
          was alleged under section 6013(e).3  Initially, the Moores were             
          pro se in docket No. 27274-96 and on July 27, 1998, entries of              
          appearance were filed on behalf of the Moores by Attorneys Wendy            
          S. Pearson and Terri A. Merriam.  Attorney Merriam filed an                 
          amendment to the petition on August 24, 1998, alleging an                   
          alternative legal theory, but no mention of section 6013(e) or              
          innocent spouse relief was contained in the amended pleading.               

               3 Sec. 6013(e) was the predecessor to sec. 6015 allowing,              
          under certain circumstances, relief from joint and several tax              
          liability.  At times, these provisions were referred to as                  
          “innocent spouse” provisions.                                               

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