Hopkins v. Comm'r
United States Tax Court
P and H filed joint returns for 1982, 1983, 1984, 1988, and 1989. Adjustments to partnership deductions and NOL deductions resulted in tax deficiencies for 1982, 1983, and 1984. The partnership deductions are attributable to H's partnership. The NOL deductions are attributable to P's property. P and H reported taxes due on their joint returns for 1988 and 1989; however, they failed to pay those amounts.
Read the full summary
P and H filed joint returns for 1982, 1983, 1984, 1988, and 1989. Adjustments to partnership deductions and NOL deductions resulted in tax deficiencies for 1982, 1983, and 1984. The partnership deductions are attributable to H's partnership. The NOL deductions are attributable to P's property. P and H reported taxes due on their joint returns for 1988 and 1989; however, they failed to pay those amounts. After P and H were separated, P filed a request for relief under sec. 6015, I.R.C., with respect to her joint and several tax liabilities for 1982, 1983, 1984, 1988, and 1989. Held: P is not…
1Opinion of the Court
Ruwe, Judge:
The issue for decision is whether petitioner is entitled to relief from joint and several liability under section 6015(b), (c), or (f)1 for her 1982, 1983, 1984, 1988, and 1989 income tax liabilities. Those tax liabilities, which include deficiencies, interest, penalties, and underpayments, are as follows:
Year Liability
1982 . $216,040.49
1983 . 154,412.96
1984 . 21,181.26
1988 . 2,496.38
1989 . 3,598.37
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time of…
2Cases cited13 opinions
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- United States v. RyersonSupreme Court of the United States · 1941
- Cheshire v. CommissionerUnited States Tax Court · 2000
- Alt v. Comm'rUnited States Tax Court · 2002
- Kathryn Cheshire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2002
8 more not listed; retrieve them via the Exa API.
3Cited by51 opinions
- Ewing v. Comm'rUnited States Tax Court · 2004
- Pullins v. CommissionerUnited States Tax Court · 2011
- Gray v. CommissionerUnited States Tax Court · 2012
- Friday v. Comm'rUnited States Tax Court · 2005
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
46 more not listed; retrieve them via the Exa API.