Belk v. Comm'r
United States Tax Court
Held, petitioner's entitlement to innocent spouse relief determined; held, further, petitioner is liable for additions to tax pursuant to sec. 6651(a)(1).
1Opinion of the Court
WHITAKER, Judge:
By statutory notice dated May 27, 1986, respondent determined deficiencies in and additions to the Federal income tax of Henderson Belk and petitioner Ann E. Belk for the years and in the amounts as follows:
Fiscal year ending Deficiency Sec. 6651(a)(1)1
June 30, 1976 $505,312 $126,328
June 30, 1977 3,443 861
June 30, 1981 212,541 10,627
The deficiencies arise primarily from the investment activities of petitioner’s former husband, Henderson Belk. The issues before us are: (1) Whether petitioner qualifies for innocent spouse relief pursuant to section 6013(e) for 1976 and 19812 and…
2Cases cited7 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- Purcell v. CommissionerUnited States Tax Court · 1986
- Mysse v. CommissionerUnited States Tax Court · 1972
- Douglas v. CommissionerUnited States Tax Court · 1986
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- Philip Friedman, Anna Friedman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1995
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