United States DC Circuit

The Tax Court properly denied "innocent spouse" relief under 26 U.S.C. section 6015, where a widow did not know in fact of any understatement of tax, but knew every fact necessary to determine that a distribution from a retirement system was fully taxable and not excludable.

Appellate Information

• Argued 12/04/2001
• Decided 06/14/2002
• Published 06/14/2002

Judges

• Before:  SENTELLE and ROGERS, Circuit Judges, and WILLIAMS, Senior Circuit Judge.

Court

• United States DC Circuit

Counsel

• For Appellant:
  
• Richard B. Treanor argued the cause and filed the briefs for appellants.


• For Appellees:
  
• Joan I. Oppenheimer, Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief was David English Carmack, Attorney.