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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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