Mark Buchine v. Commissioner of Internal Revenue Service, Karen C. Buchine v. Commissioner of Internal Revenue Service

REYNALDO G. GARZA, Circuit Judge:

Mark and Karen Buchine appeal a decision from the United States Tax Court holding them hable for tax deficiencies. We find that the Tax Court did not go beyond its statutorily prescribed jurisdiction by applying the equitable principle of reformation. We further find that the Tax Court did not clearly etr in finding that a written agreement existed between each of the Buchines and the IRS, and in finding that Karen Buchine was not an innocent spouse within the meaning of I.R.C. § 6013(e). Therefore, the decision of the Tax Court is AFFIRMED.

I. FACTS

Mark and…