-4-
On March 22, 1982, petitioner filed a petition for divorce
with the Superior Court of California, Contra Costa County.3
On April 8, 1982, respondent's answer in the proceeding before
this Court was filed. Petitioners did not file a reply to the
answer. Accordingly, on May 20, 1982, respondent filed a Motion
for Entry of Order that Undenied Allegations in Answer Be Deemed
Admitted. On June 23, 1982, we granted that motion.
On February 3, 1986, a Stipulation of Settled Issues was filed
with this Court relating solely to petitioners' investment in the
Investors Mining Program 77-5. It was signed by petitioner, Dr.
Scrimshaw, their then attorney, and an Internal Revenue Service
(IRS) special trial attorney. On March 12, 1987, a Stipulation of
Settlement relating solely to that investment was filed with the
Court, signed by petitioner, Dr. Scrimshaw, their then attorney,
and Assistant District Counsel in New York. Petitioner read,
reviewed, and signed these documents.
On October 5, 1990, respondent prepared computations of
petitioners' 1975-79 tax liability, reflecting the following
changes to the adjustments made in the notice of deficiency: (1)
On their 1978 and 1979 tax returns, petitioners claimed losses of
$36,032.00 and $16,118.00, respectively from their investment in
3 In the divorce settlement, Dr. Scrimshaw was awarded
petitioners' interests in Investors Mining Program 77-5 and Cable
TV-Tele Communications as his separate property "subject to all
liens, encumbrances, assessments and/or tax liabilities which
Respondent [Dr. Scrimshaw] shall pay and hold Petitioner [Mrs.
Scrimshaw] harmless thereon."
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