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PURCELL v. C.I.R.

No. 86-1678.

826 F.2d 470 (1987)

Joyce PURCELL, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided August 18, 1987.

Rehearing and Rehearing Denied October 5, 1987.

Attorney(s) appearing for the Case

Alan L. Cates (argued), Morgan & Garner, Chattanooga, Tenn., for petitioner-appellant.

Jean Owens, Acting Counsel, I.R.S., Michael L. Paup, Roger M. Olsen, Tax Div., Dept. of Justice, Washington, D.C., Gilbert S. Rothenberg, Teresa E. McLaughlin (argued), for respondent-appellee.

Before KENNEDY, JONES and RYAN, Circuit Judges.

Rehearing and Rehearing En Banc Denied October 5, 1987.

CORNELIA G. KENNEDY, Circuit Judge.

Purcell ("appellant") appeals the decision of the tax court upholding the Commissioner's assessment of an income tax deficiency for the tax years 1977 and 1978. The tax court concluded that section 6013(e) of the Internal Revenue Code, the innocent spouse provision, did not relieve appellant from liability for the tax resulting from allocation of a portion of the proceeds...

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