Legal Opinion

Carmel v. Commissioner

United States Tax Court

Decided March 11, 1992No. Docket No. 27300-89Published

R issued a notice of deficiency to P and his wife, in which she determined adjustments to nonpartnership items reported on income tax returns jointly filed by P and his wife. P and his wife also reported losses on their returns attributable to P's wife's interest in a partnership; however, any adjustments to these losses are not issues before the Court.

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R issued a notice of deficiency to P and his wife, in which she determined adjustments to nonpartnership items reported on income tax returns jointly filed by P and his wife. P and his wife also reported losses on their returns attributable to P's wife's interest in a partnership; however, any adjustments to these losses are not issues before the Court. P filed a separate petition with this Court in which he claimed that he is entitled to innocent spouse relief under sec. 6013(e) with respect to the partnership items. P and R agree that there are no deficiencies in and additions to tax due…

1Opinion of the Court

Peter W. Carmel, Petitioner v. Commissioner of Internal Revenue, Respondent

Carmel v. Commissioner

Docket No. 27300-89

United States Tax Court

98 T.C. 265; 1992 U.S. Tax Ct. LEXIS 25; 98 T.C. No. 20;

March 11, 1992, Filed

An appropriate order and decision will be entered.

R issued a notice of deficiency to P and his wife, in which she determined adjustments to nonpartnership items reported on income tax returns jointly filed by P and his wife. P and his wife also reported losses on their returns attributable to P's wife's interest in a partnership; however, any adjustments to these losses are not…

2Cases cited5 opinions

  1. Maxwell v. CommissionerUnited States Tax Court · 1986
  2. N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
  3. Trost v. CommissionerUnited States Tax Court · 1990
  4. Carmel v. CommissionerUnited States Tax Court · 1992
  5. Dynamic Energy, Inc. v. CommissionerUnited States Tax Court · 1992

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