Legal Opinion

Ketchum v. Commissioner

United States Tax Court

Decided December 7, 1981No. Docket No. 6032-78Published

H and W filed a joint Federal income tax return for 1974, reporting a loss on Schedule E attributable to X, a subch. S corporation owned by H. Respondent determined that X should have reported taxable income of $ 24,982.74, rather than the earlier claimed loss.

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H and W filed a joint Federal income tax return for 1974, reporting a loss on Schedule E attributable to X, a subch. S corporation owned by H. Respondent determined that X should have reported taxable income of $ 24,982.74, rather than the earlier claimed loss. Respondent therefore disallowed the loss claimed by H and W on their individual return, and further asserted a deficiency for the failure to report income of $ 24,982.74. W did not contest respondent's determination on the merits, but rather sought relief as an "innocent spouse." Held, amounts disclosed on the subch. S return cannot be…

1Opinion of the Court

Susan L. Ketchum, Petitioner v. Commissioner of Internal Revenue, Respondent

Ketchum v. Commissioner

Docket No. 6032-78

United States Tax Court

77 T.C. 1204; 1981 U.S. Tax Ct. LEXIS 15;

December 7, 1981, Filed

Decision will be entered under Rule 155.

H and W filed a joint Federal income tax return for 1974, reporting a loss on Schedule E attributable to X, a subch. S corporation owned by H. Respondent determined that X should have reported taxable income of $ 24,982.74, rather than the earlier claimed loss. Respondent therefore disallowed the loss claimed by H and W on their individual return, and…

2Cases cited18 opinions

  1. Bettye A. Sanders v. United StatesCourt of Appeals for the Fifth Circuit · 1975
  2. Sonnenborn v. CommissionerUnited States Tax Court · 1971
  3. Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1975
  4. Adams v. CommissionerUnited States Tax Court · 1973
  5. Quinn v. CommissionerUnited States Tax Court · 1974

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