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1984 income tax, pursuant to section 6653(a)(1) and (2), in the
amounts of $200 and $2,756, respectively. The additions to tax
are attributable to a partnership loss from the American Indian
Venture Capital Partnership (the partnership) that was claimed on
the 1983 joint income tax return and carried forward to the 1984
return. The underlying adjustments relating to the partnership
were resolved in American Indian Venture Capital v. Commissioner,
docket No. 17697-87. A timely petition was filed in response to
the statutory notice issued on April 3, 1992. At the time of
filing the petition herein, petitioner resided in Ellicott City,
Maryland.
Petitioner, through her attorney, Peter Driscoll, filed a
petition for redetermination on July 9, 1992. Petitioner argued
that she is not liable for the additions to tax because she is an
innocent spouse within the meaning of section 6013(e).
Petitioner also argues that the statute of limitations bars
assessment and collection of the tax.
On September 4, 1992, respondent filed an answer to the
petition in which she denied all substantive allegations of fact
and error and affirmatively alleged as a defense that the statute
of limitations does not bar assessment and collection of the
deficiency due for the taxable year 1984. Respondent alleged as
follows:
and Procedure.
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