Douglas v. Commissioner
United States Tax Court
Petitioner filed a joint return with her husband for 1979 and 1980. He subsequently died, and petitioner was unable to substantiate the full amount of the deductions claimed on the returns for employee business expenses for transportation and alimony.
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Petitioner filed a joint return with her husband for 1979 and 1980. He subsequently died, and petitioner was unable to substantiate the full amount of the deductions claimed on the returns for employee business expenses for transportation and alimony. Held, petitioner is not entitled to relief as an innocent spouse under sec. 6013(e), I.R.C. 1954, because she did not show that the disallowed deductions had "no basis in fact or law" within the meaning of sec. 6013(e)(2)(B), I.R.C. 1954.
1Opinion of the Court
OPINION
FEATHERSTON, Judge:
Respondent determined deficiencies in the amounts of $5,781.69 and $873 in petitioner’s Federal income taxes for 1979 and 1980, respectively, and an addition to tax under section 6653(a), I.R.C. 1954,1 in the amount of $289.08 for 1979. After concessions, including the addition to tax, the issue for decision is whether petitioner is relieved from liability under section 6013(e) with respect to the income tax resulting from the disallow-; anee of claimed deductions for alimony and employee business expenses.
All the facts are stipulated.
Petitioner Leora L. Douglas…
2Cases cited1 opinion
- Purcell v. CommissionerUnited States Tax Court · 1986
3Cited by64 opinions
- Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- Bokum v. CommissionerUnited States Tax Court · 1990
- Flynn v. CommissionerUnited States Tax Court · 1989
- Donald Feldman and Patricia Feldman, A/K/A Patsy Jane Feldman v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1994
- Belk v. Comm'rUnited States Tax Court · 1989
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