Dorene Bulger - Page 4

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          appointed Mr. Hoyt to act on their behalf with regard to                    
          partnership matters and reaffirmed their prior debt assumption              
          agreement with the Hoyt partnership.                                        
               Petitioner and Mr. Bulger filed joint Federal income tax               
          returns for 1985 through 1987, on which they claimed substantial            
          losses and investment credits related to their SGE investment,              
          and a Form 1045, Application for Tentative Refund, on which they            
          carried back an investment credit attributable to SGE to 1982,              
          1983, and 1984.  The SGE deductions and credits the Bulgers                 
          claimed significantly reduced their taxable income and overall              
          Federal income tax liabilities for 1982 through 1987.  Following            
          an audit and related litigation,3 respondent adjusted the Hoyt              
          partnership losses and investment credits claimed on Mr. Bulger’s           
          1982 and 1983 individual Federal income tax returns and                     
          petitioner and Mr. Bulger’s returns for 1984 through 1987 and               
          assessed substantial income tax deficiencies for 1984 through               
          1987.                                                                       
               On or about July 10, 2000, petitioner submitted Form 8857,             
          Request for Innocent Spouse Relief (And Separation of Liability             
          and Equitable Relief), on which she requested relief from joint             




               3According to respondent, litigation regarding petitioner’s            
          and Mr. Bulger’s investment in SGE was resolved by this Court’s             
          order and decision, entered on Nov. 27, 1996, in Shorthorn                  
          Genetic Engg. 1985-1, Ltd. v. Commissioner, docket No. 22069-89.            





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