Betty Bell Wissing v. Commissioner of Internal Revenue

ORDER

This appeal is from a decision of the Tax Court that the appellant is jointly and severally liable with her ex-husband for income taxes on unreported income in 1963, 1964, and 1965, under authority of section 6013(d) (3) of the Internal Revenue Code of 1954, 26 U.S.C. § 6013 (d) (3), which unequivocally provides that “if a joint return is made, * * * the liability with respect to the tax shall be joint and several.” It is undisputed that the appellant’s husband embezzled more than $100,000 over a three year period which constituted taxable, but unreported income. Appellant had no…