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MITCHELL v. C.I.R.S.

No. 01-1045.

292 F.3d 800 (2002)

Herbert L. MITCHELL, et al. Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided June 14, 2002.

Attorney(s) appearing for the Case

Richard B. Treanor argued the cause and filed the briefs for appellants.

Joan I. Oppenheimer, Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief was David English Carmack, Attorney.

Before: SENTELLE and ROGERS, Circuit Judges, and WILLIAMS, Senior Circuit Judge.

Opinion for the Court filed by Circuit Judge SENTELLE.

SENTELLE, Circuit Judge:

This case is before us on appeal by the taxpayer from a decision of the Tax Court denying "innocent spouse" relief under 26 U.S.C. § 6015. We affirm that decision for the reasons that follow.

I. Background

The facts necessary to this decision are not in dispute. See Mitchell v. Commissioner, 80 T.C.M. (CCH) 590, 2000...

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