- 5 - In February of 1985, petitioners separated, and on October 13, 1987, their divorce became final. In the divorce decree, several of the investments previously held only in Isaac’s name were designated as owned by Isaac and Lora jointly, including the equipment leasing partnership investments giving rise to the stipulated deficiencies. On audit of petitioners’ joint Federal income tax returns for 1979, 1980, 1981, and 1982, respondent determined deficiencies in petitioners’ Federal income taxes, based largely on the disallowance of claimed interest expense and partnership losses relating to two of the equipment leasing partnerships. Specifically, respondent determined that the partnership losses claimed with respect to the equipment leasing partnerships were not allowable because petitioners did not establish that the alleged partnership transactions constitute bona fide, arm’s- length transactions, entered into at fair market value, that such transactions were entered into for profit, or that such transactions had any economic substance. Respondent also determined that the claimed interest expense deductions relating to the equipment leasing partnerships were not allowable because petitioners had not shown that the claimed expenses arose from a bona fide debtor-creditor relationship. On July 12, 2000, Lora filed a Form 8857, Request for Innocent Spouse Relief, with regard to the above income taxPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011