ROGERS v. C.I.R.

No. 17-3358.

908 F.3d 1094 (2018)

Frances L. ROGERS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided November 19, 2018.


Attorney(s) appearing for the Case

John Edward Rogers , Attorney, ROGERS & ASSOCIATES, Evanston, IL, for Petitioner-Appellant.

Bruce R. Ellisen , Attorney, Rachel I. Wollitzer , Attorney, Department of Justice, Tax Division, Appellate Section, Gilbert Steven Rothenberg , Attorney, Department of Justice, Office of the Attorney General, Washington, DC, for Respondent-Appellee.

Before Bauer, Easterbrook, and Scudder, Circuit Judges.


A married couple's choice to file a joint federal income tax return results in both individuals assuming full liability for any owed tax. Frances Rogers and her husband John did so for 2004. When the Internal Revenue Service subsequently found the return deficient, the Rogerses pushed back, ultimately took the IRS to trial...

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