Marianne Hopkins - Page 5

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          interest in this entity.  They reported a $951 section 1231 gain            
          from Shelter Associates III on their joint return for 1984.4                
               Petitioner and Mr. Hopkins’s reported income for 1980                  
          through 1984 was significantly offset by partnership losses,5 a             
          casualty loss, and net operating loss (NOL) carrybacks and                  
          carryforwards that they claimed as deductions.                              
               Petitioner and Mr. Hopkins claimed deductions on their joint           
          returns for 1982 and 1983 which related to Far West Drilling                
          partnership.6  The Far West Drilling partnership deductions were            
          attributable to Mr. Hopkins’s investment in that partnership.               
          The deductions related to the Far West Drilling partnership were            
          erroneous.  Petitioner and Mr. Hopkins signed a closing agreement           
          under section 7121 in which they agreed to adjustments to the Far           
          West Drilling partnership deductions.  In a separate opinion,               
          Hopkins v. Commissioner, 120 T.C. ___ (2003), we held that                  


               4A Schedule K-1, Partner’s Share of Income, Credits,                   
          Deductions, etc., for 1984 reports petitioner as a partner in               
          Shelter Associates III.                                                     
               5Petitioner and Mr. Hopkins deducted substantial losses from           
          various partnership activities on their 1980, 1982, and 1983                
          joint income tax returns:  The first page of each of the 1980,              
          1982, and 1983 joint returns showed losses on Schedule E,                   
          Supplemental Income and Loss, of $119,408, $88,383, and $26,844,            
          respectively.  The partnership activities included Circle T                 
          Racing Stable, Shelter Associates III, San Sierra Investment #11,           
          ECC Leveraged Drilling #3, and Far West Drilling.                           
               6They 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.               




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