Isaac Baranowicz and Lora D. Baran, f.k.a. Lorraine D. Baranowicz - Page 5

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               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 tax                 






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