Carmel v. Commissioner
United States Tax Court
R issued a notice of deficiency to P and his wife, in which she determined adjustments to nonpartnership items reported on income tax returns jointly filed by P and his wife. P and his wife also reported losses on their returns attributable to P's wife's interest in a partnership; however, any adjustments to these losses are not issues before the Court.
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R issued a notice of deficiency to P and his wife, in which she determined adjustments to nonpartnership items reported on income tax returns jointly filed by P and his wife. P and his wife also reported losses on their returns attributable to P's wife's interest in a partnership; however, any adjustments to these losses are not issues before the Court. P filed a separate petition with this Court in which he claimed that he is entitled to innocent spouse relief under sec. 6013(e) with respect to the partnership items. P and R agree that there are no deficiencies in and additions to tax due…
1Opinion of the Court
OPINION
CLAPP, Judge:
This case is before the Court on the parties' cross-motions for entry of decision. All section references are to the Internal Revenue Code for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
On August 15,1989, respondent issued a notice of deficiency to petitioner and his wife for the taxable years 1984 and 1985. Respondent made adjustments to nonpartnership items reported on the income tax returns jointly filed by petitioner and his wife, and determined deficiencies in and additions to tax for both years.…
2Cases cited4 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Trost v. CommissionerUnited States Tax Court · 1990
- Dynamic Energy, Inc. v. CommissionerUnited States Tax Court · 1992
3Cited by10 opinions
- Keener v. United StatesUnited States Court of Federal Claims · 2007
- Bradley v. CommissionerUnited States Tax Court · 1993
- Crop Assocs.-1986 v. CommissionerUnited States Tax Court · 1999
- Bradley v. CommissionerUnited States Tax Court · 1993
- Carmel v. CommissionerUnited States Tax Court · 1992
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