Estate of Krock v. Commissioner
United States Tax Court
H and W understated their joint tax liabilities in an amount in excess of $ 2.2 million. P contests R's determination by claiming that W was an innocent spouse within the meaning of sec. 6013(e), I.R.C. 1954. P argues that it would be inequitable to hold W's estate liable because W did not receive benefits from the uncontested understatements, other than normal support.
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H and W understated their joint tax liabilities in an amount in excess of $ 2.2 million. P contests R's determination by claiming that W was an innocent spouse within the meaning of sec. 6013(e), I.R.C. 1954. P argues that it would be inequitable to hold W's estate liable because W did not receive benefits from the uncontested understatements, other than normal support. P argues that H and W were "wealthy" before, during, and after the years in issue and that W's lifestyle was always consistent with that wealth. Held: P bears the burden of proving that W received no significant benefit from…
1Opinion of the Court
. RUWE, Judge:
In a notice of deficiency dated June 18, 1973, respondent determined deficiencies in the joint Federal income taxes of Edward and Miriam Krock and additions to tax for the taxable years 1965 through 1969 as follows:
Additions to tax
Year Deficiency sec. 6653(b)1
1965 $109,600.98 $54,800.49
1966 840,825.72 420,412.86
1967 811,227.64 405,613.82
1968 477,665.21 238,832.60
1969 44,878.36 22,439.18
2,284,197.91 1,142,098.95 Total
In a second notice of deficiency dated December 13, 1973, respondent determined a deficiency in the joint Federal income tax of Edward and Miriam Krock and an…
2Cases cited7 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
- Terzian v. CommissionerUnited States Tax Court · 1979
2 more not listed; retrieve them via the Exa API.
3Cited by70 opinions
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- Porter v. Comm'rUnited States Tax Court · 2009
- Jacquelyn Hayman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Melinda B. Resser v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
- Winnett v. CommissionerUnited States Tax Court · 1991
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