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request for relief from joint tax liability pursuant to section
6015(b) or (f).1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference.
At the time the petition was filed, petitioner resided in
Pittsburgh, Pennsylvania.
The Deficiencies and Tax Court Cases
For the years 1980 through 1983, petitioner and her husband,
Richard E. Doyle (the Doyles), timely filed joint Federal income
tax returns on which they deducted expenses associated with
various tax shelters, including horse breeding and racing tax
shelters.2 Respondent audited the Doyles’ 1980 through 1983 tax
returns and disallowed the claimed tax shelter deductions.
Respondent issued notices of deficiency to the Doyles determining
tax deficiencies and penalties in excess of $100,000.
The Doyles timely filed petitions with this Court seeking
redetermination of deficiencies for the tax years 1980 through
1983. The cases, docket Nos. 6518-87 and 9855-88, were tried in
1Except as indicated to the contrary, all section references
are to the Internal Revenue Code as amended.
2For example, on their 1980 return, the Doyles claimed tax
shelter deductions of $69,721 on gross income of $101,053.
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Last modified: May 25, 2011