Isaac Baranowicz v. Commissioner of Internal Revenue

Isaac Baranowicz (“Baranowicz”) appeals the United States Tax Court’s deter mination that his former wife, Lora Baran (“Baran”), is entitled to “innocent spouse” relief under § 6015(c) of the Internal Revenue Code (“I.R.C.”). The tax deficiency-in dispute resulted from several deductions claimed on the couple’s joint tax returns that were subsequently disallowed by the Commissioner. Following the couple’s divorce in 1987, Baran sought, and was granted, “innocent spouse” relief under § 6015(c). On appeal, Baranowicz contends that the Tax Court erred by granting such relief to Baran and allocating the tax deficiencies solely to Baranowicz. We conclude that Baranowicz lacks standing to appeal the Tax Court’s decision; therefore, we dismiss thq appeal.

BACKGROUND

Baranowicz and Baran were married in 1966. During the years 1979, 1980, 1981, and 1982, the couple took pass-through depreciation deductions attributable to limited partnership interests in equipment leasing ventures similar to those deemed improper tax shelters. See, e.g., Whitmire v. Commissioner, 178 F.3d 1050 (9th Cir. 1999); Waters v. Commissioner, 978 F.2d 1310 (2d Cir.1992); Young v. Commissioner, 926 F.2d 1083 (11th…