Anne C. Somervill - Page 2

                                                                  - 2 -                                                                       
                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.                                                                                   




Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011