- 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
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