United States Fifth Circuit

Where putative innocent spouse knew or had reason to know of tax understatement, under either the knowledge-of-the-transaction or the erroneous deduction test, the district court's denial of innocent spouse relief under sections 6015(b), (c), and (f) of the Internal Revenue Code, was not clearly erroneous.

Appellate Information

• Decided 02/08/2002
• Published 02/08/2002

Judges

• KING, Chief Judge:, Before KING, Chief Judge, DAVIS, Circuit Judge, and VANCE, District Judge.

Court

• United States Fifth Circuit

Counsel

• For Appellant:
  
• John Edward Leeper (argued), Law Office of Joseph Abraham, Jr., El Paso, TX, for Petitioner-Appellant.


• For Appellees:
  
• Joan I. Oppenheimer (argued), David English Carmack, U.S. Dept. of Justice, Tax Div., Charles Casazza, Clerk, U.S. Tax Court, Richard W. Skillman, Chief Counsel, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Washington, DC, for Respondent-Appellee.