Resnick v. Commissioner
United States Tax Court
Petitioner filed a joint Federal income tax return with her former husband for the taxable year 1968. Respondent determined a deficiency for 1968 based upon an overstatement in the cost of goods sold by her former husband in his business as a dealer in coins.
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Petitioner filed a joint Federal income tax return with her former husband for the taxable year 1968. Respondent determined a deficiency for 1968 based upon an overstatement in the cost of goods sold by her former husband in his business as a dealer in coins. Held, petitioner does not qualify for relief from an agreed deficiency for 1968 as an innocent spouse under sec. 6013(e), I.R.C. 1954, because the tax liability resulted from respondent's decrease of cost of goods sold rather than from his inclusion in gross income of an amount erroneously omitted from gross income.
1Opinion of the Court
Ann B. Resnick, Petitioner v. Commissioner of Internal Revenue, Respondent
Resnick v. Commissioner
Docket No. 575-72
United States Tax Court
63 T.C. 524; 1975 U.S. Tax Ct. LEXIS 195;
February 3, 1975, Filed
Decision will be entered under Rule 155.
Petitioner filed a joint Federal income tax return with her former husband for the taxable year 1968. Respondent determined a deficiency for 1968 based upon an overstatement in the cost of goods sold by her former husband in his business as a dealer in coins. Held, petitioner does not qualify for relief from an agreed deficiency for 1968 as an innocent…
2Cases cited4 opinions
- Sonnenborn v. CommissionerUnited States Tax Court · 1971
- Galliher v. CommissionerUnited States Tax Court · 1974
- Resnick v. CommissionerUnited States Tax Court · 1975
- Rodman v. CommissionerUnited States Tax Court · 1973