- 10 -
Although Barbara was not present when David met the
promoters of Vulcan and executed the subscription agreement and
the notes, she later reviewed the subscription agreement, and
David gave her a general explanation of the nature of the
investment, expressing the view that it would provide substantial
tax savings to them.
The subscription agreement contained the following
representation by all those purchasing a limited partnership
interest:
I am aware that the tax effects which may be expected
by the Partnership are not susceptible to certain
prediction, and new developments in rulings of the
Internal Revenue Service, court decisions, or
legislative changes may have an adverse effect on one
or more of the tax consequences sought by the
Partnership.
Request for Section 6015 Relief
On June 13, 2000, David submitted to respondent a Form 8857,
Request for Innocent Spouse Relief (And Separation of Liability
and Equitable Relief) (the Form 8857), on behalf of the “Estate
of Barbara J. Jonson”. David signed the Form 8857: “David C.
Jonson (Personal Representative)”. Among the attachments to the
Form 8857 is a document entitled “Statement of Estate of Barbara
J. Jonson * * * by David C. Jonson, Personal Representative”, in
which David states: “Any financial benefits that resulted to the
Jonson family [from Vulcan] went into the general funds
administered by David. It eventually contributed to their normal
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