United States Sixth Circuit

A judgment upholding income tax deficiencies and fraud-penalty assessments levied by the IRS against petitioners is affirmed where the tax court did not clearly err in finding that: 1) petitioner-husband fraudulently created sham trusts and underreported the couple's income'; and 2) petitioner-wife failed to show that she was entitled to innocent-spouse relief.

Appellate Information

• Decided 12/11/2007
• Published 12/11/2007

Judges

• Before:  MARTIN, GIBBONS, and SUTTON, Circuit Judges.

Court

• United States Sixth Circuit

Counsel

• For Appellees:
  
• ARGUED:  Robert Alan Jones, Las Vegas, Nevada, for Petitioners. Andrea R. Tebbets, United States Department of Justice, Washington, D.C., for Respondent.   ON BRIEF:  Robert Alan Jones, Las Vegas, Nevada, for Petitioners.  Andrea R. Tebbets, Joan I. Oppenheimer, United States Department of Justice, Washington, D.C., for Respondent.