- 16 - Each individual who elects the application of section 6015(c) shall have the burden of proof with respect to establishing the portion of any deficiency allocable to such individual. Sec. 6015(c)(2). Respondent argues that a portion of the Far West Drilling deductions is attributable to petitioner. He relies upon petitioner’s testimony in a prior Tax Court case that did not concern petitioner’s or Mr. Hopkins’s investments in partnerships. Petitioner testified under cross-examination in that case: Q Isn’t it a fact, Mrs. Hopkins, that during 1980 you invested money into Far West Drilling? A Yes. Q And wasn’t that at least $22,000? A Yes. In the instant case, petitioner testified that she misunderstood the question; that she understood the question to refer to both her and Mr. Hopkins; and that she personally invested nothing in Far West Drilling. Petitioner’s testimony is supported by correspondence from Far West Drilling and a note that Mr. Hopkins signed in favor of the partnership, which indicates that Mr. Hopkins invested in Far West Drilling. The record also contains 17(...continued) deficiency and allocable to the individual under paragraph (3) bears to the net amount of all items taken into account in computing the deficiency.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011