Marianne Hopkins - Page 3

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time of filing the           
          petition, petitioner resided in Kentfield, California.                      
               Petitioner was formerly married to Donald K. Hopkins.2                 
          Petitioner filed joint income tax returns with Mr. Hopkins from             
          1978 to 1997.  Petitioner and Mr. Hopkins claimed deductions on             
          their joint returns for 1982 and 1983, which related to a certain           
          Far West Drilling partnership.  They claimed a loss deduction of            
          $83,402 on their joint return for 1982.  They claimed a loss                
          deduction of $91,086 and a depletion deduction of $2,126 on their           
          joint return for 1983.  Those deductions were erroneous.                    
               Respondent audited the Far West Drilling partnership.  In              
          the course of respondent’s examination, petitioner and Mr.                  
          Hopkins agreed to settle their tax liabilities relating to Far              
          West Drilling.  They signed a Form 906, Closing Agreement on                
          Final Determination Covering Specific Matters, dated September              
          28, 1988.  The closing agreement provides:                                  
                    Under section 7121 of the Internal Revenue Code                   
               Donald K and Marianne Hopkins 111 Diablo DR.,                          
               Kentfield, CA 94904  * * *  and the Commissioner of                    
               Internal Revenue make the following closing agreement:                 



               2Petitioner and Mr. Hopkins were separated on Feb. 1, 1989.            
          At some point thereafter, they were divorced.                               




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