- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011