George C. Scrimshaw and Erna C. Scrimshaw - Page 4

                                         -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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