Rebecca Jo Reser v. Commissioner of Internal Revenue

WIENER, Circuit Judge:

Petitioner-Appellant Rebecca Jo Reser (Reser) appeals the Tax Court’s decision disallowing certain deductions that she and her former husband, Don C. Reser (Don), claimed on their 1987 and 1988 joint income tax returns. The deductions represented losses incurred by Don’s subchapter S corporation for those years. Reser asserts, in the alternative, that she is not hable for any deficiency determined by the Tax Court on the 1987 joint return, as she is an innocent spouse, as defined in 26 U.S.C. § 6013(e). Although we affirm the Tax Court’s disallowance of the questioned…