ROBERTS v. C.I.R.

No. 87-4931.

860 F.2d 1235 (1988)

Bobbie J. ROBERTS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

November 14, 1988.


Attorney(s) appearing for the Case

Ben A. Douglass, Douglas, Kressler & Wuester, Fort Worth, Tex., for petitioner-appellant.

William F. Nelson, Chief Counsel, IRS, Janet A. Bradley, Gary R. Allen, Wm. S. Rose, Jr., Jonathan S. Cohen, Asst. Attys. Gen., Tax Div., Washington, D.C., for respondent-appellee.

Before WILLIAMS and GARWOOD, Circuit Judges, and NOWLIN, District Judge.


NOWLIN, District Judge:

Bobbie J. Roberts ("Taxpayer") appeals from an adverse decision of the Tax Court. The Tax Court held that Taxpayer knew or should have known of a real estate kickback received by her husband in 1975 and should therefore be taxed on her community property interest in that kickback. The Tax Court also held that Taxpayer did not have reasonable cause for failing to timely file a tax return for the year 1975 and should therefore be liable for an...

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