Legal Opinion

Rosenthal v. Comm'r

United States Tax Court

Decided March 26, 2004No. 2601-01UnpublishedCited by 13 opinions

P and H filed a joint 1996 Federal income tax return on which H failed to report a taxable distribution from his individual retirement account (IRA). P was not aware of the existence of the IRA distribution at the time the 1996 return was filed. The omission was discovered in 1998 and, on Nov. 22, 1998, after H's death on Sept. 1, 1998, P filed an amended 1996 return and paid the additional tax attributable to the omitted income.

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P and H filed a joint 1996 Federal income tax return on which H failed to report a taxable distribution from his individual retirement account (IRA). P was not aware of the existence of the IRA distribution at the time the 1996 return was filed. The omission was discovered in 1998 and, on Nov. 22, 1998, after H's death on Sept. 1, 1998, P filed an amended 1996 return and paid the additional tax attributable to the omitted income. P also paid the interest on the additional tax on Feb. 10, 1999. P claimed relief from joint liability for the additional tax under sec. 6015(b), (c), and (f),…

1Opinion of the Court

CATHERINE ROSENTHAL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Rosenthal v. Comm'r

No. 2601-01

United States Tax Court

T.C. Memo 2004-89; 2004 Tax Ct. Memo LEXIS 87; 87 T.C.M. (CCH) 1183;

March 26, 2004, Filed

Decision will be entered for petitioner.

P and H filed a joint 1996 Federal income tax return on

which H failed to report a taxable distribution from his

individual retirement account (IRA). P was not aware of the

existence of the IRA distribution at the time the 1996 return

was filed. The omission was discovered in 1998 and, on Nov. 22,

1998, after H's death on Sept. 1, 1998, P…

2Cases cited13 opinions

  1. United States v. RyersonSupreme Court of the United States · 1941
  2. Mysse v. CommissionerUnited States Tax Court · 1972
  3. Alt v. Comm'rUnited States Tax Court · 2002
  4. Jonson v. Comm'rUnited States Tax Court · 2002
  5. Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003

8 more not listed; retrieve them via the Exa API.

3Cited by13 opinions

  1. Billings v. Comm'rUnited States Tax Court · 2006
  2. Minihan v. Comm'rUnited States Tax Court · 2012
  3. Torrisi v. Comm'rUnited States Tax Court · 2011
  4. Thomassen v. Comm'rUnited States Tax Court · 2011
  5. Bland v. Comm'rUnited States Tax Court · 2011

8 more not listed; retrieve them via the Exa API.

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