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partnership accompanied by Schedules K-1, Partner’s Share of
Income, Deductions, Credits, etc., reporting their shares of
partnership losses. Petitioners never realized any income from
their investments in the partnership.
Petitioners claimed on their joint Federal income tax
returns for the subject years deductions for their distributive
shares of losses reported by the partnership. At all relevant
times, petitioner knew about her investment in the partnership,
and she knew that she was a limited partner. In 1981, respondent
notified petitioners that the partnership was under investigation
and that losses generated by the partnership might be disallowed.
After 1981, petitioners ceased deducting losses from the
partnership on their Federal income tax returns.
Respondent disallowed the partnership loss deductions
petitioners claimed on their Federal income tax returns for the
subject years. The disallowance resulted in the deficiencies in
tax for which petitioner seeks spousal relief. Those
deficiencies were assessed pursuant to stipulated decisions
entered by this Court in a deficiency suit brought by
petitioners.
During the subject years, petitioner was responsible for
balancing the couple’s checkbook, and she had full access to
their joint bank accounts. She was not abused physically or
mentally by Golden during those years.
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Last modified: November 10, 2007