Donna M. Sutherland v. Comm’r, No. 3634-18, T.C. Memo 2021-110 | September 16, 2021 | Lauber | Dkt. No. 3634-18
Short Summary: This is an innocent spouse case in which the taxpayer, Ms. Sutherland, sought relief from joint and several liability under the equitable relief provision of 26 U.S.C. 6015(f). The Court ultimately found that the taxpayer was not entitled to the relief requested.
- Did the taxpayer qualify for relief from joint and several liability for the unpaid employment taxes that accrued from taxpayer’s husband’s business?
Facts and Primary Holdings:
- The taxpayer was married to her husband Scott in 1990. She has a high school education and completed a few college courses. She gave birth to the couple’s only child in 1991, and after her child was born, she worked primarily at home or in Scott’s business.