Estate of Simmons v. Commissioner
United States Tax Court
D and her husband filed a joint income tax return for 1986 in which they failed to calculate and report the proper alternative minimum tax. Held: The failure to calculate and report alternative minimum tax does not constitute a "grossly erroneous item" within the meaning of sec. 6013(e)(2), I.R.C. 1954. Thus, D does not qualify for relief from liability as an innocent spouse under sec. 6013(e).
1Opinion of the Court
Estate of Virginia V. Simmons, Deceased, Virginia H. Wilder, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Simmons v. Commissioner
Docket No. 120-89
United States Tax Court
94 T.C. 682; 1990 U.S. Tax Ct. LEXIS 45; 94 T.C. No. 40;
May 2, 1990, Filed
Decision will be entered for the respondent.
D and her husband filed a joint income tax return for 1986 in which they failed to calculate and report the proper alternative minimum tax. Held: The failure to calculate and report alternative minimum tax does not constitute a "grossly erroneous item" within the meaning of…
2Cases cited9 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- 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
- Flynn v. CommissionerUnited States Tax Court · 1989
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