Dorothy D. McGee v. Commissioner of Internal Revenue

Dorothy McGee appeals the decision of the tax court, McGee v. Commissioner, 62 T.C.M. (CCH) 976 (1991), denying her relief under I.R.C. § 66(c), and finding her liable for additions to tax under I.R.C. §§ 6651(a)(1), 6653(a)(1) & (2), and 6654. Finding that the tax court’s findings of fact were not clearly erroneous, we affirm.

I

Taxpayer is a college graduate and a nurse by training. In 1977, she married Dr. Daniel Tache, a dentist. From 1977 to 1980, Tache had little income from dentistry 1 and taxpayer worked as a clinical nurse. They filed joint federal income tax returns during this period.