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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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