Legal Opinion
Joyce Purcell v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided October 5, 1987No. 86-1678PublishedCited by 178 opinions
1Opinion of the Court
CORNELIA G. KENNEDY, Circuit Judge.
Purcell (“appellant”) appeals the decision of the tax court upholding the Commissioner’s assessment of an income tax deficiency for the tax years 1977 and 1978. The tax court concluded that section 6013(e) of the Internal Revenue Code, the innocent spouse provision, did not relieve appellant from liability for the tax resulting from allocation of a portion of the proceeds from the sale of appellant’s stock in a corporation to a covenant not to compete because appellant had actual knowledge of the covenant. The tax court also concluded that the innocent…
2Cases cited6 opinions
- Purcell v. CommissionerUnited States Tax Court · 1986
- Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
- Sally A. Shea v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Douglas v. CommissionerUnited States Tax Court · 1986
- Sivils v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.
3Cited by178 opinions
- Bokum v. CommissionerUnited States Tax Court · 1990
- Madeline M. Stevens v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1989
- Jonson v. Comm'rUnited States Tax Court · 2002
- Patricia A. Price v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1989
- Porter v. Comm'rUnited States Tax Court · 2009
173 more not listed; retrieve them via the Exa API.