Gwen Gullible was married to Darrell Devious. They were divorced two years ago. Three years ago (the year before their divorce), Darrell received a

$250,000 retirement plan distribution, of which $50,000 was rolled over into an IRA. At the time, Gwen was aware of the retirement funds and the rollover.

The distribution was used to pay off the couple’s mortgage, purchase a car, and for living expenses. Darrell prepared the couple’s joint return, and Gwen asked him about the tax ramifications of the retirement distributions. He told her he had consulted a CPA and was advised that the retirement plan proceeds used to pay off a mortgage were not taxable income. Gwen accepted that explanation and signed the return. In fact, Darrell had not consulted a CPA.

One year ago (after the divorce), Gwen received a letter from the IRS saying they had not received the tax return for the last full year of marriage. On advice from a CPA, Gwen immediately filed the return (she had a copy of the unfiled return). The Internal Revenue Service notified Gwen that no estimated payments on the retirement distribution had been paid by Darrell, and that she owed $60,000 in tax, plus penalties and interest.

a. List as many possible tax research issues as you can to determine whether Gwen is liable for the tax, interest, and penalties.

b. After completing your list of tax research issues, list the keywords you might use to construct a computer tax research query.

c. Execute a computer search using your query. For simplicity, select the IRS Revenue Rulings database from the computer tax service you use. Summarize your findings.