-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."Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011