Corson v. Commissioner
United States Tax Court
Ps T and J filed a joint Federal income tax return for the taxable year 1981, and R issued a notice of deficiency for taxes, additions to tax, and interest related thereto. Ps filed a joint petition for redetermination with this Court, and J later amended the petition to assert a claim for innocent spouse relief.
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Ps T and J filed a joint Federal income tax return for the taxable year 1981, and R issued a notice of deficiency for taxes, additions to tax, and interest related thereto. Ps filed a joint petition for redetermination with this Court, and J later amended the petition to assert a claim for innocent spouse relief. Subsequently, J and R entered into a stipulation in which J conceded liability for the deficiencies determined by R but preserved her right to pursue innocent spouse relief. T and R then signed a similar stipulation settling all issues pertaining to T's tax liabilities for the 1981…
1Opinion of the Court
OPINION
Nims, Judge:
This matter is before the Court on respondent’s motion for entry of decision. Broadly stated, the issue to be resolved is whether objection by petitioner Thomas Corson to respondent’s settlement with petitioner Judith Corson, granting her relief under section 6015(c) from joint and several liability, provides sufficient basis for the Court to deny respondent’s motion for entry of decision. As more narrowly framed by the contentions of the parties, the question raised is whether provisions of the Internal Revenue Service Restructuring and Reform Act of 1998 (Restructuring…
2Cases cited9 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- Woods v. CommissionerUnited States Tax Court · 1989
- Fernandez v. CommissionerUnited States Tax Court · 2000
- Krause v. CommissionerUnited States Tax Court · 1992
4 more not listed; retrieve them via the Exa API.
3Cited by77 opinions
- Jonson v. Comm'rUnited States Tax Court · 2002
- Ewing v. Comm'rUnited States Tax Court · 2004
- King v. CommissionerUnited States Tax Court · 2000
- Porter v. Comm'rUnited States Tax Court · 2008
- Commissioner v. NealCourt of Appeals for the Eleventh Circuit · 2009
72 more not listed; retrieve them via the Exa API.