Legal Opinion

Janet Bliss v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided July 12, 1995No. 963, Docket 94-4051PublishedCited by 22 opinions

1Opinion of the Court

JACOBS, Circuit Judge:

The Commissioner of Internal Revenue has asserted a tax deficiency against petitioner Janet Bliss arising out the 1982 joint tax return she signed with her former husband. Petitioner appeals from an order of the United States Tax Court (Laurence J. Whalen, Judge) sustaining the deficiency. Without objecting to the Commissioner’s assessment or calculation of the deficiency or the penalties, petitioner argued before the Tax Court that she was entitled to relief from liability as an innocent spouse under 26 U.S.C. § 6013(e). In general, this equitable exception applies to…

2Cases cited6 opinions

  1. Sonnenborn v. CommissionerUnited States Tax Court · 1971
  2. Madeline M. Stevens v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1989
  3. Patricia A. Price v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1989
  4. Jacquelyn Hayman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
  5. Philip Friedman, Anna Friedman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1995

1 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. Kathryn Cheshire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2002
  2. Rebecca Jo Reser v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1997
  3. Melinda B. Resser v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
  4. Braune v. Abbott LaboratoriesDistrict Court, E.D. New York · 1995
  5. Estate of Frederick Carl Gloeckner, Deceased, Joseph A. Simone, and Douglas Dillon v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998

17 more not listed; retrieve them via the Exa API.

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