Sonnenborn v. Commissioner
United States Tax Court
H and W, owners of all the stock of M Corp., filed joint Federal income tax returns for 1965, 1966, and 1967. The Commissioner determined that certain expenditures and payments by M (including "Payments charged to loan account") constituted constructive dividends to H and W. H has conceded the deficiencies and W does not contest their correctness but seeks merely to be relieved of liability therefor under the "innocent spouse" provisions of sec. 6013(e), I.R.C. 1954. The…
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H and W, owners of all the stock of M Corp., filed joint Federal income tax returns for 1965, 1966, and 1967. The Commissioner determined that certain expenditures and payments by M (including "Payments charged to loan account") constituted constructive dividends to H and W. H has conceded the deficiencies and W does not contest their correctness but seeks merely to be relieved of liability therefor under the "innocent spouse" provisions of sec. 6013(e), I.R.C. 1954. The record establishes affirmatively that W knew or had reason to know that there was at least some unreported income during…
1Opinion of the Court
Tbe Commissioner determined deficiencies in petitioners’ income tax in tbe years and amounts as follows:
Tear Deficiency
1965 -$27,446.68
1966 - 39,383.34
1967 - 13,371.25
Petitioner Jerome J. Sonnenborn bas conceded that be is liable for tbe deficiencies as determined by tbe Commissioner. Petitioner Ethel G. Sonnenbom similarly does not contest the correctness of the deficiencies but presents merely the isssue as to whether she is relieved of liability in respect thereof by section 6013 (e), I.B.C. 1954.
FINDINGS OF FACT
Jerome J. and Ethel G. Sonnenbom are husband and wife. They filed joint…
2Cases cited6 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Pollack v. CommissionerUnited States Tax Court · 1966
- Stoumen v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
1 more not listed; retrieve them via the Exa API.
3Cited by186 opinions
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- Bettye A. Sanders v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Mysse v. CommissionerUnited States Tax Court · 1972
- Bokum v. CommissionerUnited States Tax Court · 1990
- Nicholas v. CommissionerUnited States Tax Court · 1978
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