Mysse v. Commissioner
United States Tax Court
1. H, the cashier of a small town bank, misappropriated substantial amounts from the bank which he failed to report in the joint Federal income tax refunds he filed with his wife, W. Held, minimum amounts of H's unreported income determined. 2. Held, further, W is relieved of her joint liability for the deficiencies in income tax under sec. 6013(e), I.R.C. 1954. 3. Held, further, transferee liability attaches to certificates of deposit purchased by H for W and their son and…
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1. H, the cashier of a small town bank, misappropriated substantial amounts from the bank which he failed to report in the joint Federal income tax refunds he filed with his wife, W. Held, minimum amounts of H's unreported income determined. 2. Held, further, W is relieved of her joint liability for the deficiencies in income tax under sec. 6013(e), I.R.C. 1954. 3. Held, further, transferee liability attaches to certificates of deposit purchased by H for W and their son and to funds received by W as the survivor joint tenant of a bank account which was created by H while he was insolvent.
1Opinion of the Court
FeatherstoN, Judge:
These three consolidated proceedings involve disputed income tax deficiencies and transferee liabilities. In a notice of deficiency addressed to Arne O. Mysse (deceased) and Patricia E. Mysse (docket No. 2611-69), respondent determined tbe following deficiencies in income tax:
Year Amount
1963 _$12,192. 75
1964 _ 6, 002.93
1965 _ 29,772.16
1966 _ 29,709. 77
Jeopardy assessments were made of these amounts, together with interest, on April 4,1969. Patricia E. Mysse (hereinafter referred to as Patricia) seeks a redetermination of the deficiencies as to her, but no petition has been…
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