Stiteler v. Commissioner
United States Tax Court
Ps filed joint Federal income tax returns for the taxable years in issue. H invested in numerous tax shelters during those years. R determined that Ps could not claim deductions from those shelters and determined deficiencies in their Federal income taxes. R and Ps settled the amount of their deficiencies, but W claims that she is entitled to innocent spouse relief under section 6013(e), I.R.C.
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Ps filed joint Federal income tax returns for the taxable years in issue. H invested in numerous tax shelters during those years. R determined that Ps could not claim deductions from those shelters and determined deficiencies in their Federal income taxes. R and Ps settled the amount of their deficiencies, but W claims that she is entitled to innocent spouse relief under section 6013(e), I.R.C. Held: W is not entitled to innocent spouse relief because she has not proven that it would be inequitable to hold her liable for the deficiencies attributable to the tax understatements.
1Opinion of the Court
JOHN B. STITELER AND ELIZABETH L. STITELER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Stiteler v. Commissioner
Docket No. 15520-90
United States Tax Court
T.C. Memo 1995-279; 1995 Tax Ct. Memo LEXIS 276; 69 T.C.M. (CCH) 2975;
June 21, 1995, Filed
Decision will be entered under Rule 155.
Ps filed joint Federal income tax returns for the taxable years in issue. H invested in numerous tax shelters during those years. R determined that Ps could not claim deductions from those shelters and determined deficiencies in their Federal income taxes. R and Ps settled the amount of their…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bettye A. Sanders v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- Purcell v. CommissionerUnited States Tax Court · 1986
- Bokum v. CommissionerUnited States Tax Court · 1990
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