- 4 - they appointed Mr. Hoyt to act on their behalf with regard to partnership matters and reaffirmed their prior debt assumption agreement with the Hoyt partnership. Petitioner and Mr. Owen filed joint Federal income tax returns for 1982 through 1996 on which they claimed substantial losses and an investment credit related to their DGE investment. The DGE deductions and credits claimed by the Owens significantly reduced their taxable income and overall Federal income tax liabilities for 1982 through 1996. As a result of our decision in Shorthorn Genetic Engg. 1982-2, Ltd. v. Commissioner, T.C. Memo. 1996-515, on July 18, 1997, petitioner and Mr. Owen entered into a closing agreement with respondent concerning the tax consequences of the DGE investment, which resulted in income tax deficiencies for 1982 through 1995.3 On April 29, 2000, Mr. Owen died. On or about July 21, 2000, petitioner submitted Form 8857, Request for Innocent Spouse Relief (And Separation of Liability and Equitable Relief), on which she requested relief from joint and several liability for 1982 to 1997. Petitioner attached a supporting statement to the request in which she represented that she was not involved in the DGE investment and did not financially benefit from it. Petitioner argued that she met each requirement of section 3Under the closing agreement, petitioners were not liable for any deficiencies in income tax for 1996 or 1997.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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