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1982 34,128 1 10,255
1To be determined.
All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
After concessions, the issue for decision is whether
petitioner qualifies as an innocent spouse with respect to any
portion of the income tax deficiencies.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation and the attached exhibits are incorporated herein
by this reference.
Petitioner resided in Harlingen, Texas, at the time the
petition was filed. Petitioner and her then husband, Robert C.
Somervill,1 filed joint Federal income tax returns for all of the
years in issue. Respondent issued a notice of deficiency on
April 2, 1993, for the tax years 1976 through 1982. Respondent's
notice of deficiency disallowed in full the ordinary losses from
an investment in Oxnard Properties, a partnership, claimed by
petitioner and Robert Somervill on their joint Federal income tax
returns for certain of the years in issue. Additionally, the
notice disallowed an investment tax credit carryback from 1979 to
1Petitioner and Robert C. Somervill divorced in 1985 but
were married throughout the years in issue.
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