Jonson v. Comm'r
United States Tax Court
H and W filed joint Federal income tax returns for 1981 and 1982 on which they took large deductions attributable to a tax shelter investment. R disallowed the deductions. W claimed relief from joint liability under sec. 6013(e), I.R.C., which was repealed and replaced by sec. 6015, I.R.C.
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H and W filed joint Federal income tax returns for 1981 and 1982 on which they took large deductions attributable to a tax shelter investment. R disallowed the deductions. W claimed relief from joint liability under sec. 6013(e), I.R.C., which was repealed and replaced by sec. 6015, I.R.C. W died while still married to and living with H. Ps concede the deficiencies but pursue the sec. 6015, I.R.C. claim on behalf of W. Ps allege that, although W was aware of the tax shelter investment, the anticipated tax savings, and the tax risks, she qualifies for relief under sec. 6015(b)(1), (c), and…
1Opinion of the Court
Halpeen, Judge:
By notice of deficiency dated April 14, 1987, respondent determined deficiencies in, and additions to, the Federal income tax liabilities of David C. and Barbara J. Jonson (separately, David or Barbara; together, the Jon-sons), as follows:1
Sec. 6659 TYE Deficiency addition
1981 $32,998 CO 00 05 to
1982 33,504 O © CO QO
On account of concessions made by the parties (which we accept),2 the sole issue for our decision is whether Barbara is relieved of any liability for tax pursuant to the provisions of section 6015.3
Unless otherwise noted, all section references are to the Internal…
2Cases cited23 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- National Taxpayers Union, Inc. v. United StatesCourt of Appeals for the D.C. Circuit · 1995
- Purcell v. CommissionerUnited States Tax Court · 1986
- Bokum v. CommissionerUnited States Tax Court · 1990
18 more not listed; retrieve them via the Exa API.
3Cited by124 opinions
- Alt v. Comm'rUnited States Tax Court · 2002
- Porter v. Comm'rUnited States Tax Court · 2009
- Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
- Washington v. Comm'rUnited States Tax Court · 2003
- Mendes v. Comm'rUnited States Tax Court · 2003
119 more not listed; retrieve them via the Exa API.