- 18 - in ANA 367, as reported on the joint returns for 1982 and 1983 as petitioner’s item, are allocable to petitioner. As to 1984 and 1985, however, respondent argues that the amounts allocable to petitioner should be increased to reflect the tax benefit that petitioner received from items allocated to Trupin to the extent that those items gave rise to a tax benefit for petitioner, i.e., deductions reducing petitioner’s earned income. Sec. 6015(d)(3)(B); Hopkins v. Commissioner, 121 T.C. 73, 83-85 (2003). Respondent also traces various assets that were transferred to petitioner by Trupin within the period for which transfers are presumed to have as their principal purpose the avoidance of tax or payment of tax and other transfers that respondent has shown to have as a principal purpose the avoidance of tax or payment of tax. Petitioner’s only response to the detailed analysis in respondent’s brief of transfers reflected in the stipulation is that Trupin was repaying loans to her. Petitioner’s explanation is unpersuasive. She has stipulated that her net worth as of December 31, 1981, did not exceed $250,000. Because she refused to provide information concerning her assets in response to Court-ordered discovery, she was prohibited from presenting documentary or testimonial evidence relating to the assets that she owned since 1980 or her annual net worth for each year since 1980. All pre-existing debts owed by Trupin to petitioner werePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011