Renee Trupin D'Aunay - Page 18

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          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 were             






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