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Residence
At the time of the petition, the Jonsons resided in Golden,
Colorado.
The Joint Returns
For 1981 and 1982 (the audit years), the Jonsons made joint
returns of income (the 1981 joint return, the 1982 joint return,
and, collectively, the joint returns). Among the attachments to
the 1981 joint return is a Schedule K-1, Partner’s Share of
Income, Credits, Deductions, Etc. – 1981, identifying David as a
limited partner in a partnership, Vulcan Oil Technology (Vulcan),
and showing, as a “distributive share item”, a loss of $75,620.
Such loss is further reflected on a Schedule E, Supplemental
Income and Loss Schedule, attached to the 1981 joint return and
in a composite figure carried from such Schedule E to the first
page of the 1981 joint return, where such composite figure is
deducted. The Schedule K-1 also shows that David’s interest in
Vulcan’s profits, losses, and capital is 1.415 percent. The
facts are similar for 1982, except that the amount of the loss is
$71,078 (the losses for 1981 and 1982 being referred to,
collectively, as the Vulcan losses).
David prepared the joint returns. Barbara knew that the
Vulcan losses were claimed on those returns.
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Last modified: May 25, 2011