KING v. COMMISSIONER OF INTERNAL REVENUE
United States Tax Court
P claimed relief from joint liability under sec. 6013(e), I.R.C., which was repealed and replaced by sec. 6015, I.R.C. Intervenor (I) is P's former spouse, who intervened pursuant to sec. 6015(e)(4), I.R.C., in opposition to P's claim for relief.
Read the full summary
P claimed relief from joint liability under sec. 6013(e), I.R.C., which was repealed and replaced by sec. 6015, I.R.C. Intervenor (I) is P's former spouse, who intervened pursuant to sec. 6015(e)(4), I.R.C., in opposition to P's claim for relief. See King v. Commissioner, 115 T.C. 118 (2000). P and I filed a joint income tax return for 1993, on which they claimed a loss from a cattle-raising activity conducted by I. The loss was disallowed by R on the ground that the activity was not engaged in for profit under sec. 183(a), I.R.C. 1. HELD: P meets all the requirements for relief under sec.…
1Opinion of the Court
OPINION
Ruwe, Judge:
This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Couvillion, Special Trial Judge:
Respondent determined a deficiency of $7,781 in petitioner’s Federal income tax for 1993.
The sole issue for decision is whether petitioner is entitled to relief from joint liability under section 6015. The underlying deficiency determined by respondent in the notice of deficiency is not…
2Cases cited9 opinions
- Golanty v. CommissionerUnited States Tax Court · 1979
- Siegel v. CommissionerUnited States Tax Court · 1982
- Bokum v. CommissionerUnited States Tax Court · 1990
- Cheshire v. CommissionerUnited States Tax Court · 2000
- Richard D. Bokum, Ii, Margaret B. Bokum v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
4 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Kathryn Cheshire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2002
- Mora v. Comm'rUnited States Tax Court · 2001
- Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, and Naomi Kanter v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2003
- Sowards v. Comm'rUnited States Tax Court · 2003
- Barnes v. Comm'rUnited States Tax Court · 2004
21 more not listed; retrieve them via the Exa API.