Pamela J. Ellison - Page 10

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          and Mr. Ellison for 1985 and 1986 list the following under the              
          area for partner’s name:  “Don & Pamela Ellison”.4                          
               In 1986, petitioner and Mr. Ellison applied for a refund of            
          their 1982, 1983, and 1984 taxes in the amounts of $1,629, $833,            
          and $2,097, respectively.                                                   
               On June 16, 1998, respondent mailed petitioner and Mr.                 
          Ellison two letters and reports explaining computational                    
          adjustments made to their 1982, 1983, 1984, 1985, and 1986                  
          returns as a result of adjustments made to the partnership                  
          returns of DGE 1984-2 for 1985 and 1986.  These computational               
          adjustments resulted from the Court’s opinion in Shorthorn                  
          Genetic Engg. 1982-2, Ltd. v. Commissioner, T.C. Memo. 1996-515.            
          Request for Relief From Joint and Several Liability                         
               On or about July 17, 2000, petitioner mailed respondent a              
          Form 8857, Request for Innocent Spouse Relief (and Separation of            
          Liability and Equitable Relief).5  Betty Sneed and Bonnie Halbert           
          were assigned to review petitioner’s request for section 6015               
          relief.                                                                     


               4  This is also true for the years subsequent to the years             
          in issue (1987 through 1995).                                               
               5  Petitioner requested relief for the tax years 1982                  
          through 1997.  On Nov. 14, 2000, respondent mailed petitioner a             
          letter advising her that the request was premature for the years            
          1987 through 1997 as the request related to a potential                     
          assessment from a TEFRA (Tax Equity and Fiscal Responsibility Act           
          of 1982, Pub. L. 97-248, 96 Stat. 324) partnership proceeding               
          that, as of that date, had not been concluded.                              





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