Bacher v. Commissioner
United States Tax Court
H and W filed joint income tax returns for the taxable years 1961 through 1964 which substantially understated their gross income for such years.
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H and W filed joint income tax returns for the taxable years 1961 through 1964 which substantially understated their gross income for such years. H has conceded the deficiencies determined by the Commissioner, and W does not challenge their correctness but seeks relief from liability therefor under the innocent spouse provisions of sec. 6013(e), I.R.C. 1954. Held: (1) For 1961, W has failed to prove that there was a 25-percent omission of income attributable to H as required by sec. 6013(e)(1)(A), I.R.C. 1954; (2) for 1962, she has failed to prove that she lacked knowledge of the omitted…
1Opinion of the Court
GERSON BACHER and MILDRED BACHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bacher v. Commissioner
Docket No. 7958-73.
United States Tax Court
T.C. Memo 1977-82; 1977 Tax Ct. Memo LEXIS 362; 36 T.C.M. (CCH) 363; T.C.M. (RIA) 770082;
March 24, 1977, Filed
H and W filed joint income tax returns for the taxable years 1961 through 1964 which substantially understated their gross income for such years. H has conceded the deficiencies determined by the Commissioner, and W does not challenge their correctness but seeks relief from liability therefor under the innocent spouse provisions…
2Cases cited25 opinions
- Bettye A. Sanders v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Sonnenborn v. CommissionerUnited States Tax Court · 1971
- Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
- Quinn v. CommissionerUnited States Tax Court · 1974
- Bailey v. SmithSupreme Court of Florida · 1925
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