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PARK v. C.I.R.

No. 93-5339.

25 F.3d 1289 (1994)

Harold L. PARK, Deceased, and Alice P. Jones, formerly Alice P. Park, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

June 30, 1994.

Attorney(s) appearing for the Case

Thomas E. Redding, Charles B. Koerth, Redding, Coselli, Tinsley & Allie, L.L.P., Houston, TX, for appellant.

Abraham N.M. Shashy, Jr., Chief Counsel, IRS, John A. Nolet, Gary R. Allen, Chief, Kenneth L. Greene, Appellate Section, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellee.

Before GOLDBERG, KING, and WIENER, Circuit Judges.

KING, Circuit Judge:

Alice P. Jones appeals the decision of the United States Tax Court denying her innocent spouse relief under 26 U.S.C. § 6013(e) and § 6004 of the Technical and Miscellaneous Revenue Act of 1988. Finding no error, we affirm.

I. BACKGROUND

A. FACTUAL BACKGROUND

Harold Park and Alice Jones were married in 1978. Park was a certified public accountant and chief financial officer for Thomas Petroleum Products. Jones...

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