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Petitioner has resided in a house located at 111 Diablo
Drive, Kentfield, California, since 1967. Petitioner was the
sole owner of the house during the tax years at issue.2
Petitioner filed joint income tax returns with Mr. Hopkins
from 1978 to 1997.3 They reported Mr. Hopkins’s wages of
$141,683, $166,906, and $162,654 as income on their joint returns
for 1982, 1983, and 1984, respectively. They reported income
from a State tax refund of $5,039 on their joint return for 1982.
The refund matches the amount of State income taxes withheld from
Mr. Hopkins’s wages for 1981. They reported interest income of
$8,148, $5,192, and $2,107 on their joint returns for 1982, 1983,
and 1984, respectively. The evidence does not show who owned the
principal that generated the interest. Petitioner and Mr.
Hopkins reported ordinary income of $68,452 from San Sierra
Investment #11 on their joint return for 1983. The evidence does
not show who owned the partnership interest. They reported
ordinary income of $2,751 from ECC Leveraged Drilling on their
joint return for 1984. The evidence does not show who owned the
2The real property located at 111 Diablo Drive consists of
two parcels. Petitioner and Mr. Hopkins acquired parcel 1 in
1967. On Apr. 2, 1973, Mr. Hopkins quitclaimed his interest in
parcel 1, which included the house, to petitioner. Petitioner is
still the sole owner of parcel 1. Parcel 2 has been held by
petitioner and Mr. Hopkins as joint tenants since it was acquired
in 1973.
3On the joint returns for 1980 through 1984, petitioner’s
occupation is listed as “investor”.
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