Marianne Hopkins - Page 10

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          reduced their reported tax liabilities to zero.10  The losses               
          from the partnership activities for 1982 and 1983 were largely              
          attributable to the Far West Drilling deductions.  The joint                
          return for 1982 showed a Far West Drilling partnership deduction            
          of $83,402.  The joint return for 1983 showed a Far West Drilling           
          partnership deduction of $91,086 and a depletion deduction of               
          $2,126.  Those amounts far exceeded other partnership deductions            
          which were claimed in the joint returns.                                    
               Petitioner, at the very least, understood the general                  
          concepts of Federal income taxation,11 and she demonstrated to us           
          no discernible difficulty in understanding English.  Petitioner             
          was involved in the audit process with respect to the 1982 and              
          1983 joint returns.  At some point during the Internal Revenue              
          Service (IRS) audit of those returns, petitioner and Mr. Hopkins            
          were represented by John E. Lahart.12  Mr. Lahart spoke with                
          petitioner on more than one occasion, and he testified that she             

               10However, in prior years, petitioner and Mr. Hopkins                  
          reported relatively large tax liabilities, $24,229 in 1978 and              
          $22,684 in 1979, but reported insignificant partnership                     
               11An individual cannot rely solely on ignorance of the                 
          attendant tax or legal consequences of an item giving rise to a             
          deficiency to satisfy his or her burden under sec. 6015(b)(1)(C).           
          See Price v. Commissioner, 887 F.2d 959, 964 (9th Cir. 1989).               
               12Petitioner and Mr. Hopkins signed a Form 2848, Power of              
          Attorney and Declaration of Representative, dated Sept. 22, 1988,           
          in which they appointed Mr. Lahart to represent them before the             
          Internal Revenue Service (IRS).                                             

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