- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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