Mora v. Comm'r
United States Tax Court
H invested in a tax shelter limited partnership that passed through substantial losses that were claimed on the joint Federal income tax returns H and W filed for the taxable years 1985 and 1986, and disallowed by R. After H and W were divorced W sought relief from joint and several liability. R denied W's request for relief from joint and several liability under sec. 6015(b) and (c), I.R.C., on the ground that W had knowledge of the items giving rise to the deficiencies.
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H invested in a tax shelter limited partnership that passed through substantial losses that were claimed on the joint Federal income tax returns H and W filed for the taxable years 1985 and 1986, and disallowed by R. After H and W were divorced W sought relief from joint and several liability. R denied W's request for relief from joint and several liability under sec. 6015(b) and (c), I.R.C., on the ground that W had knowledge of the items giving rise to the deficiencies. Held, W is not entitled to relief from joint and several liability under sec. 6015(b), I.R.C.; W had reason to know of the…
1Opinion of the Court
PATRICIA M. MORA, F.K.A. PATRICIA RASPBERRY, Petitioner, AND LYNN RASPBERRY, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mora v. Comm'r
No. 6154-00
United States Tax Court
117 T.C. 279; 2001 U.S. Tax Ct. LEXIS 54; 117 T.C. No. 23;
December 17, 2001, Filed
Petitioner was not entitled to relief from joint and several liability under 6015(b) I.R.C. Petitioner was entitled to relief under 6015(c) I.R.C.
H invested in a tax shelter limited partnership that passed
through substantial losses that were claimed on the joint
Federal income tax returns H and W filed for the taxable years
1985 and…
2Cases cited12 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Patricia A. Price v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1989
- Jacquelyn Hayman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Dolan v. CommissionerUnited States Tax Court · 1965
- James A. Guth, and Arlys M. Guth v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1990
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