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WIKSELL v. C.I.R.

No. 94-70509.

90 F.3d 1459 (1996)

Margaret WIKSELL, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 25, 1996.

Attorney(s) appearing for the Case

Bruce I. Hochman, Charles P. Rettig, and Joanna Tulio, Hochman, Salkin & DeRoy, Beverly Hills, California, for petitioner-appellant.

Sara S. Holderness, Tax Division, United States Department of Justice, Washington, D.C., for respondent-appellee.

Before: WALLACE and T.G. NELSON, Circuit Judges, and WILLIAM D. BROWNING, District Judge.

WILLIAM D. BROWNING, District Judge:

I.

In 1987, Margaret Wiksell signed two joint tax returns for the years 1984 and 1985, both of which omitted substantial ill-gotten income generated by her (now ex) husband's illicit business. Margaret Wiksell claims to have known nothing about most of the money taken nor anything about the scam that generated the funds. On March 7, 1991, a notice of deficiency was issued to the Wiksells for tax years 1984 and 1985. The...

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