Flynn v. Commissioner
United States Tax Court
P claims to be an innocent spouse entitled to relief under sec. 6013(e), I.R.C. 1954, for the years 1974, 1975, and 1976. In order to qualify for such relief, P must establish that the understatements of tax were attributable to "grossly erroneous items." The deficiencies result from adjustments increasing income and decreasing losses from two subch. S corporations in which P's former husband was a shareholder.
Read the full summary
P claims to be an innocent spouse entitled to relief under sec. 6013(e), I.R.C. 1954, for the years 1974, 1975, and 1976. In order to qualify for such relief, P must establish that the understatements of tax were attributable to "grossly erroneous items." The deficiencies result from adjustments increasing income and decreasing losses from two subch. S corporations in which P's former husband was a shareholder. Held: 1. Secs. 1373 (prior to its 1982 amendment effective for years after 1982) and 6013(e) require that an increase to a shareholder's reported income from a subch. S corporation be…
1Opinion of the Court
Joan K. Flynn, Petitioner v. Commissioner of Internal Revenue, Respondent
Flynn v. Commissioner
Docket No. 35109-83
United States Tax Court
93 T.C. 355; 1989 U.S. Tax Ct. LEXIS 127; 93 T.C. No. 31;
September 20, 1989September 20, 1989, Filed
Decision will be entered under Rule 155.
P claims to be an innocent spouse entitled to relief under sec. 6013(e), I.R.C. 1954, for the years 1974, 1975, and 1976. In order to qualify for such relief, P must establish that the understatements of tax were attributable to "grossly erroneous items." The deficiencies result from adjustments increasing income and…
2Cases cited18 opinions
- Bettye A. Sanders v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Sonnenborn v. CommissionerUnited States Tax Court · 1971
- 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
13 more not listed; retrieve them via the Exa API.