Legal Opinion
Nancy Silverman and Estate of Sheldon Silverman, Deceased, Nancy Silverman v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 18, 1997No. 96-1680PublishedCited by 8 opinions
1Opinion of the Court
HILL, Circuit Judge.
OPINION
Appellant Nancy Silverman appeals the decision of the tax court that she fails to qualify as an “innocent spouse” under Section 6013(e) of the Internal Revenue Code and is hable for a 1981 tax deficiency generated by her (now deceased) husband’s wrongdoing. 26 U.S.C. § 6013(e). For the following reasons, we reverse.
I. FACTUAL AND PROCEDURAL BACKGROUND
In her twelve-year marriage, Nancy Silver-man was a traditional housewife. Her husband Sheldon was a successful businessman in the garment industry. Together they had two children. Other than maintaining the household…
2Cases cited12 opinions
- Joyce Purcell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- Purcell v. CommissionerUnited States Tax Court · 1986
- Sally A. Shea v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- William E. ELMORE, Plaintiff-Appellant, v. CAPSTAN, INC., Defendant-AppelleeCourt of Appeals for the Tenth Circuit · 1995
- Jennie Allen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
7 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Alt v. CommissionerCourt of Appeals for the Sixth Circuit · 2004
- Mitchell, Herbert v. Cmsnr IRSCourt of Appeals for the D.C. Circuit · 2002
- Golden v. CommissionerCourt of Appeals for the Sixth Circuit · 2008
- Flores v. United StatesUnited States Court of Federal Claims · 2001
- Neal v. Comm'rUnited States Tax Court · 2005
3 more not listed; retrieve them via the Exa API.