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Year Deficiency
1979 $ 7,662
1980 13,123
1981 22,834
1982 16,069
The parties have also stipulated that these deficiency amounts
constitute substantial underpayments of tax attributable to tax-
motivated transactions under section 6621(c),1 and that there are
no additions to tax due from petitioners for 1980, 1981, and 1982
under section 6653(a)(1) and (2).
The issue for decision is whether petitioner Lora D. Baran
(Lora) is entitled to relief from joint and several liability
from the above deficiencies and additional interest, which relate
to investments in equipment leasing partnerships.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petitions were filed, petitioners resided in
Los Angeles, California.
Lora did not graduate from high school. Lora earned an
associate’s degree in art, but she never completed a 4-year
college degree. In 1966, petitioners married. Between 1969 and
1979, Lora was employed at various times as a clerical employee
at banks and as a legal secretary. In 1979, with the arrival of
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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Last modified: May 25, 2011