Thomas Corson and Judith Corson - Page 4




                                        - 4 -                                         
          1985, petitioners filed with this Court a joint petition                    
          contesting the notice of deficiency.  Both at that time resided             
          in the State of California.                                                 
               A test case involving the group of tax shelter partnerships            
          was thereafter litigated, and investment losses were held to be             
          nondeductible.  See Krause v. Commissioner, 99 T.C. 132 (1992),             
          affd. sub nom. Hildebrand v. Commissioner, 28 F.3d 1024 (10th               
          Cir. 1994).  Following this decision and based on its results,              
          settlement negotiations were initiated with parties in related              
          suits.                                                                      
               On June 11, 1996, Judith, now represented by separate                  
          counsel, filed a motion to amend the 1985 petition to assert her            
          entitlement to innocent spouse relief under former section                  
          6013(e).  The motion was served on attorneys for respondent and             
          for Thomas, and neither raised an objection.  The Court granted             
          Judith’s motion and filed the amendment on June 18, 1996.                   
               Then, in November of 1996, Judith and respondent entered               
          into a stipulation resolving all issues with respect to Judith              
          except that of innocent spouse relief.  The settlement stated               
          that, without considering the innocent spouse provisions of                 
          section 6013(e), an income tax deficiency of $21,711 was due from           
          Judith for the 1981 taxable year, with increased interest under             










Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011