- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011