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