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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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