Purcell v. Commissioner
United States Tax Court
Held: On the facts of record, petitioner is entitled to relief under sec. 6013(e), I.R.C. 1954, with respect to certain items of omitted income and is not entitled to such relief with respect to another item of omitted income.
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Held: On the facts of record, petitioner is entitled to relief under sec. 6013(e), I.R.C. 1954, with respect to certain items of omitted income and is not entitled to such relief with respect to another item of omitted income. Petitioner is not entitled to relief under sec. 6013(e) for disallowed deductions since not contesting respondent's disallowance of the deductions is not sufficient to establish that the deductions were "grossly erroneous" because they had no basis in fact or law.
1Opinion of the Court
SCOTT, Judge:
Respondent determined deficiencies in petitioner’s income tax for the calendar years 1977 and 1978 in the amounts of $82,955.89 and $49,749.21, respectively. The issue for decision is whether petitioner is relieved from liability under section 6013(e)1 with respect to the income tax resulting from (1) the inclusion in the income of petitioner and her then husband of (a) dividends resulting from amounts paid by a corporation of which they were stockholders for personal travel and entertainment expenses, and (b) a portion of the sales price of petitioner’s stock in another…
2Cases cited7 opinions
- Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
- Quinn v. CommissionerUnited States Tax Court · 1974
- McCoy v. CommissionerUnited States Tax Court · 1972
- Jennie Allen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
- Smith v. CommissionerUnited States Tax Court · 1978
2 more not listed; retrieve them via the Exa API.
3Cited by158 opinions
- Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- Bokum v. CommissionerUnited States Tax Court · 1990
- Jonson v. Comm'rUnited States Tax Court · 2002
- Porter v. Comm'rUnited States Tax Court · 2009
- Richard D. Bokum, Ii, Margaret B. Bokum v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
153 more not listed; retrieve them via the Exa API.