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RESSER v. C.I.R.

No. 94-3083.

74 F.3d 1528 (1996)

Melinda B. RESSER, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided January 18, 1996.

Attorney(s) appearing for the Case

Alan F. Segal, Chicago, IL, Steven D. Blanc (argued), Tully & Weinstein, Chicago, IL, Stephen M. Lewis, Cooke, Lewis, Reichstein & Lapat, Chicago, IL, for Petitioner-Appellant.

Gary R. Allen, Teresa McLaughlin, Alice L. Ronk (argued), Department of Justice, Tax Division, Appellate Section, Washington, DC, Deborah Butler, I.R.S. Office of Regional Counsel, Dallas, TX, for Respondent-Appellee.

Before BAUER, EASTERBROOK and RIPPLE, Circuit Judges.

RIPPLE, Circuit Judge.

Appellant Melinda B. Resser and her husband Alan M. Resser filed a joint federal income tax return for taxable year 1982. The United States Tax Court decided that Mr. and Mrs. Resser were liable for income tax deficiencies due to a substantial understatement of tax on their 1982 tax return. After conducting a separate trial on the reserved issue of Mrs. Resser's qualification for "innocent spouse" relief...

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