a hearing, and we conclude that a hearing is not necessary to
properly dispose of this motion. Rule 232(a)(3).
In our opinion issued on September 8, 1994, Sharer v.
Commissioner, T.C. Memo. 1994-453, we held, among other things,
that petitioner (1) was entitled to claim head of household
filing status on her returns for 1986 and 1987; (2) was entitled
to child care credits for 1986 and 1987; (3) did not have to
include in her income one-half of the income generated from an
accounting business operated by her husband during 1986 and 1987,
because this income was not community income of hers under the
community property laws of California; (4) had to include in her
income, for 1986 and 1987, payments she received from her
husband's accounting business denominated as "spousal wages",
except for a portion of the 1987 payments we determined were
repayments of loans petitioner had made to her husband; (5) was
entitled to deduct a partnership loss for 1986, because she had
substantiated her husband's basis in his partnership interest as
of the end of 1986, but was not entitled to deduct a partnership
loss for 1987, because she had not substantiated her husband's
basis in his partnership interest as of the end of 1987; (6) was
entitled to deduct all of the itemized deductions claimed on her
1986 and 1987 returns, because she had paid those deductible
expenses entirely out of her separate funds; and (7) would be
liable for various additions to tax for failure to file,
otherwise indicated.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011