- 2 -
The sole issue for decision is whether petitioner’s claim
for a refund of tax paid for 1983 and 1984 was timely. We hold
that it was not.1
Section references are to the Internal Revenue Code.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in Washington, D.C., when she filed the
petition in this case.
In 1983, petitioner was a producer for American Broadcasting
Co., Inc. She earned $135,817 as a salaried employee in 1983.
She was also a salaried employee in 1984. Petitioner’s husband
was a tax attorney. He invested in Robotics, a tax shelter, in
1983-84. Petitioner and her husband filed joint returns for 1983
and 1984 in which they reported losses and credits from Robotics.
Robotics items gave rise to deficiencies for 1983 and 1984, all
of which were attributable solely to petitioner’s husband.
Petitioner’s husband died on September 16, 1992.
1 In light of our conclusion, we need not decide whether
petitioner qualifies for equitable relief from joint liability
under sec. 6015(f).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011