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STEVENS v. C.I.R.

No. 88-3422.

872 F.2d 1499 (1989)

Madeline M. STEVENS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

May 17, 1989.

Attorney(s) appearing for the Case

Joe R. Wolfe, Clearwater, Fla., for petitioner-appellant.

William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen, Chief Robert S. Pomerance, Barbara I. Hodges, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before JOHNSON and COX, Circuit Judges, and TUTTLE, Senior Circuit Judge.

COX, Circuit Judge:

Madeline M. Stevens appeals from a decision of the tax court denying her relief under the "innocent spouse" provision of the Internal Revenue Code (the "Code"), 26 U.S.C. § 6013(e) (1982 & Supp. III 1985). The court held her jointly liable with her ex-husband, Robert L. Stevens, for personal income tax deficiencies totaling $346,301.21 for the tax years 1976 through 1979. We affirm.

I.

A.

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