Clifton Clevenger v. Commissioner of Internal Revenue

SPROUSE, Circuit Judge:

Clifton L. Clevenger appeals from the decision of the Tax Court denying him relief under the “innocent spouse” provision of the Internal Revenue Code. 26 U.S.C. § 6013(e). The court held him jointly liable with his wife Catherine for personal income tax deficiencies totaling $189,199 for the tax years 1973 through 1977. We affirm.

During the relevant years, Clifton and Catherine Clevenger each owned a fifty-percent interest in two construction contracting corporations, Clevenger Corporation and C & C Builders, Inc. Clifton was President and Catherine Secretary-Treasurer…