120 T.C. No. 17
UNITED STATES TAX COURT
MARIANNE HOPKINS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 363-01. Filed June 30, 2003.
P filed a request for relief under sec. 6015,
I.R.C., with respect to her joint and several tax
liabilities for 1982 and 1983. P and H reported loss
deductions from a partnership on their returns for
those years. In 1988, P and H signed a closing
agreement under sec. 7121, I.R.C., in which they agreed
to adjustments with respect to the partnership
deductions. The adjustments to the partnership
deductions resulted in tax deficiencies for 1982 and
1983, which R assessed. The tax liabilities for those
years were the subject of a prior bankruptcy case
involving P and H and the Government. In that case, P
raised a claim for relief from joint and several
liability under former sec. 6013(e), I.R.C. The
bankruptcy court entered judgment holding that the
closing agreement precluded P from asserting her claim
for relief under sec. 6013(e), I.R.C. A Federal
District Court and the Court of Appeals for the Ninth
Circuit affirmed the bankruptcy court’s judgment. See
Hopkins v. United States (In re Hopkins), 146 F.3d 729
(9th Cir. 1998). R argues that the closing agreement P
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