Philip H. and Anna Friedman - Page 9

                                                  - 9 -                                                    
                               Year               Income Tax Deficiency                                    
                               1981                     $41,221.00                                         
                               1982                     129,944.00                                         
                               1983                     119,644.76                                         
                               1984                     183,985.50                                         
                               1985                      501,303.00                                        
                               Total              976,098.26                                               
            Of the total of $976,098.26 for the 5 years, approximately 72                                  
            percent, or $702,791, is attributable to respondent's                                          
            disallowance of the tax shelter deductions and carryback losses                                
            which represent the "grossly erroneous item".                                                  
                  On February 4, 1991, Philip and petitioner entered into a                                
            separation agreement.  Pursuant to the agreement, Philip assigned                              
            a partnership interest to petitioner.  At the time of trial,                                   
            income distributions from the partnership amounted to $4,371 per                               
            month.  The separation agreement provided that, upon petitioner's                              
            vacating the condo, Philip would be entitled to live there and                                 
            would be required to pay all expenses, taxes, utilities, etc.                                  
            connected therewith.  By allowing Philip to reside in the condo,                               
            petitioner did not waive her ownership rights in the property.                                 
            In the event of Philip's death, petitioner would receive full                                  
            ownership of the condo.  Petitioner was given the other                                        
            residential real property and certain specific personalty which                                
            was then located in the condo.  Petitioner also received a 1986                                
            automobile under the separation agreement.                                                     
                  The separation agreement contained Federal income tax                                    
            provisions as follows:                                                                         
                  Any refund payable with respect to any joint tax                                         
                  return, now or hereafter filed, shall be paid to the                                     



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