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proceeding to determine whether petitioner is entitled to
innocent spouse relief with respect to partnership items.
Background
Some of the facts have been stipulated, and they are so
found.
In 1982, petitioner Eliane Olson (petitioner) was married to
Robert C. Olson (Mr. Olson). Petitioner and Mr. Olson were
divorced in 1984.
From 1982 until at least November 2, 1994, petitioner
resided at 5242 S. Newton Street, Littleton, Colorado (the Newton
Street address). From April 18, 1988 until at least September
26, 1995, Mr. Olson resided at 1445 E. Irish Lane, Littleton,
Colorado (the Irish Lane address). Although the record does not
indicate Mr. Olson's place of residence in 1982 to 1988, it is
clear that he did not reside with petitioner.
Notwithstanding the existence of some marital discord,
petitioner and Mr. Olson filed a joint Federal income tax return
for 1982.
In 1982, Mr. Olson was a partner with a 1.2374-percent
interest in a partnership known as Computer Graphics Partners,
Ltd. Pacific (Computer Graphics). On their income tax return for
1982, petitioner and Mr. Olson deducted Mr. Olson's distributive
share of the loss claimed by Computer Graphics on its partnership
return for that year.
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