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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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