- 22 -
in DMA Heitzman, who had been backing him in both businesses, and
the financial failure of another financial backer of Autocast.
On June 28, 1984, respondent timely issued a statutory
notice of deficiency to Mr. Heitzman and petitioner, determining
a deficiency of $55,263 for calendar year 1979. On September 20,
1984, Mr. Heitzman filed a petition with this Court in the names
of himself and petitioner, under docket No. 33436-84. On
September 26, 1984, petitioner filed a separate petition, docket
No. 33938-84, in response to the same notice. In her petition,
petitioner disputed the same factual matters as Mr. Heitzman’s
petition and raised additional issues of the period of
limitations and relief as an innocent spouse. On August 9, 1985,
Mr. Heitzman filed a motion to dismiss petitioner from the case
under docket No. 33436-84. On September 10, 1985, that motion
was granted.
On October 10, 1985, the State of Hawaii mailed Mr. Heitzman
a notice of assessment based on an increased Hawaii State income
tax liability of $11,727 that was based upon disallowance of the
deduction with respect to Stonehurst by the Internal Revenue
Service.
On December 29, 1986, Wind River sent a letter to the
Stonehurst limited partners inviting them to sign an “Agreement,
Release, Consent and Vote to Dissolve” that would terminate
Stonehurst and provide a means to “reduce” the recourse
liabilities that the limited partners had purported to assume in
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: May 25, 2011