Estate of Jackson v. Commissioner
United States Tax Court
Held: Petitioner not entitled to relief from liability under the innocent spouse provision of sec. 6013(e), I.R.C. 1954. A reasonably prudent taxpayer with her knowledge of the family finances had reason to know of the income omission.
1Opinion of the Court
Irwin, Judge:
Respondent determined a deficiency in petitioner’s income tax of $23,951.68 and an addition to tax of $11,975.84 under section 6653(b)1 for the calendar year 1971. Petitioners concede that there is a deficiency in income tax and an addition to tax due from petitioner, Estate of Henry J. Jackson, deceased, Earlene Jackson, administratrix, as determined in the notice of deficiency without taking into consideration the jeopardy assessment made in April 1974. The only question remaining for our resolution is whether petitioner, Earlene Jackson, is an innocent spouse within the…
2Cases cited3 opinions
- Bettye A. Sanders v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Sonnenborn v. CommissionerUnited States Tax Court · 1971
- Adams v. CommissionerUnited States Tax Court · 1973
3Cited by73 opinions
- Melinda B. Resser v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
- Emilia R. Pietromonaco v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Foley v. CommissionerUnited States Tax Court · 1995
- Resser v. CommissionerUnited States Tax Court · 1994
- Estate of Cardulla v. CommissionerUnited States Tax Court · 1986
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