Petitioner-appellant Jacquelyn Hayman ("Hayman") appeals from a decision entered April 21, 1992 in the United States Tax Court (Clapp, J.) sustaining the deficiency determinations made by respondent-appellee Commissioner of Internal Revenue ("Commissioner") and assessed jointly against her and her husband John Hayman ("John") for the taxable years 1977, 1978 and 1979. The Haymans reported losses from tax shelters that substantially offset their reported income for these years. The Commissioner disallowed the deductions, finding, inter alia, that the shelters were not activities entered into for profit. On appeal, the Tax Court affirmed the Commissioner's determinations and rejected Hayman's claim for relief from liability as an innocent spouse under I.R.C. § 6013(e). For the reasons that follow, we affirm.
Miner '56, Roger J., "Hayman v. CIR, 992 F. 2d 1256 - Court of Appeals, 2nd Circuit 1993" (1993). Circuit Court Opinions. 371.