McGee v. Commissioner
United States Tax Court
R issued a notice of deficiency to P determining deficiencies in and additions to P's Federal income tax for the taxable years 1982 and 1983 after P failed to file tax returns for those years. P asserts that she is not liable for the deficiencies because she is an "innocent spouse" under I.R.C. sec. 66(c). Further, P asserts that she is not liable for additions to tax because she reasonably relied on her husband and an accountant to properly report community income.
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R issued a notice of deficiency to P determining deficiencies in and additions to P's Federal income tax for the taxable years 1982 and 1983 after P failed to file tax returns for those years. P asserts that she is not liable for the deficiencies because she is an "innocent spouse" under I.R.C. sec. 66(c). Further, P asserts that she is not liable for additions to tax because she reasonably relied on her husband and an accountant to properly report community income. Held, P is not an innocent spouse as defined in I.R.C. sec. 66(c) and is liable for the deficiencies in issue. Held further, P…
1Opinion of the Court
DOROTHY D. McGEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
McGee v. Commissioner
Docket No. 17644-89
United States Tax Court
T.C. Memo 1991-510; 1991 Tax Ct. Memo LEXIS 559; 62 T.C.M. (CCH) 976; T.C.M. (RIA) 91510;
October 9, 1991, Filed
Decision will be entered for the respondent.
R issued a notice of deficiency to P determining deficiencies in and additions to P's Federal income tax for the taxable years 1982 and 1983 after P failed to file tax returns for those years. P asserts that she is not liable for the deficiencies because she is an "innocent spouse" under I.R.C. sec.…
2Cases cited7 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- United States v. MitchellSupreme Court of the United States · 1971
- Bobbie J. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Johnson v. CommissionerUnited States Tax Court · 1979
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Dorothy D. McGee v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1993