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underlying circumstances that caused the deductions to be
denied”. Petitioner also informed respondent that she had
documentation to support her contentions and offered to provide
respondent additional information upon request. In her petition,
which was filed on March 10, 2003, petitioner reiterated that she
had no actual knowledge of the factual circumstances that made
the partnership items unallowable, and she included another
recitation of supporting facts. In her petition, petitioner also
notified respondent of Mr. Bulger’s death. On April 14, 2003,
more than 2 weeks before the filing of respondent’s answer,
petitioner provided respondent with a copy of Mr. Bulger’s death
certificate.
In his answer, which was filed on May 1, 2003, respondent
denied petitioner’s representation that Mr. Bulger had died, even
though respondent had received a copy of Mr. Bulger’s death
certificate before the answer was filed. In his answer,
respondent also denied that petitioner was entitled to any
section 6015(c) relief. Neither position was reasonable under
the facts and circumstances of this case.
Respondent has consistently maintained that the partnership
investment made by petitioner and Mr. Bulger was a joint
investment, but he made no effort to evaluate the effect of his
joint investment position under section 6015(c) before he adopted
his litigating position in this case. Respondent claims that he
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