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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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