David Bruce Billings v. Commissioner

127 T.C. No. 2

UNITED STATES TAX COURT DAVID BRUCE BILLINGS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6148-03. Filed July 25, 2006. P’s wife did not report embezzlement income on their joint 1999 return. After she was caught, P and she filed an amended tax return that reported the embezzlement income. P then applied for relief from joint and several liability under IRC sec. 6015(f). The Commissioner issued a notice of determination denying his request, and P filed a petition under sec. 6015(e) to review the Commissioner’s determination. P and R stipulated that no…