Marianne Hopkins - Page 6

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          petitioner is not precluded by the closing agreement, which was             
          entered into before the enactment of section 6015, or the                   
          doctrines of res judicata and collateral estoppel from claiming             
          relief under section 6015 with respect to the tax liabilities               
          attributable to the disallowance of deductions related to the Far           
          West Drilling partnership.                                                  
               Petitioner and Mr. Hopkins reported a casualty loss of                 
          $280,661 on their joint return for 1981.  The casualty loss was             
          attributable to a mudslide that destroyed petitioner’s house.               
          Petitioner and Mr. Hopkins erroneously claimed NOL carryforward             
          deductions for 1982 and 1984 which were attributable to the                 
          casualty loss.  Petitioner agrees that the erroneous 1982 and               
          1984 NOL carryforward deductions are her items.                             
               Respondent assessed deficiencies in petitioner and Mr.                 
          Hopkins’s taxes for 1982, 1983, and 1984.  Those deficiencies               
          were attributable to the disallowance of the Far West Drilling              
          partnership deductions and the disallowance of the NOL                      
          carryforward deductions that petitioner and Mr. Hopkins claimed             
          on their joint returns for 1982, 1983, and 1984.7                           


               7Petitioner and Mr. Hopkins’s tax liability for 1982 is                
          attributable to adjustments to the NOL carryforward deduction               
          resulting from the casualty loss and the Far West Drilling                  
          partnership deduction for that year.  The tax liability for 1983            
          is attributable solely to the Far West Drilling adjustments for             
          that year.  The tax liability for 1984 arises solely from the               
          disallowance of the NOL carryforward deduction for that year.               
          Those deficiencies are not in issue.                                        




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