PURIFICATO v. C.I.R.

No. 92-7659

9 F.3d 290 (1993)

William and Marie PURIFICATO v. COMMISSIONER OF INTERNAL REVENUE SERVICE. John and Catherine PURIFICATO v. COMMISSIONER OF INTERNAL REVENUE SERVICE. William and Marie Purificato; John and Catherine Purificato, Appellants.

United States Court of Appeals, Third Circuit.

Decided November 10, 1993.


Attorney(s) appearing for the Case

Thomas W. Ostrander, Joshua Sarner (argued), Duane, Morris & Heckscher, Philadelphia, PA, for appellants.

James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Gilbert S. Rothenberg, Curtis C. Pett (argued), Attys., Tax Div., Department of Justice, Washington, DC, for appellee.

Before: BECKER, ALITO, and ROTH, Circuit Judges.


OPINION OF THE COURT

ALITO, Circuit Judge:

This is an appeal from a decision of the United States Tax Court holding that Marie and Catherine Purificato are not entitled to relief under the so-called "innocent spouse" provision of the income tax laws, 26 U.S.C. § 6013(e), and that therefore each is jointly and severally liable with her husband for amounts due as a result of the understatement of taxes on their joint returns for 1981, 1982, and 1983....

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