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The motion arises in the context of a petition filed in
response to a notice of determination concerning collection
action under section 6330 sent to petitioners and a notice of
determination concerning relief from joint liability under
section 6015 sent to Ms. Golden. Respondent moves for partial
summary judgment with respect to collection issues other than Ms.
Golden’s request for spousal relief. The section 6015 claim will
be dealt with separately at a later date.
Background
Origin of the Tax Liabilities
As alleged in the petition in this case, in 1976 and 1977,
Robert H. Golden (petitioner) invested $29,000 in a partnership
in which he had no management duties and with which he had
minimal contact. Petitioners claimed tax losses on their joint
Federal income tax returns for the years 1974 through 1981 using
information sent to them in yearly Schedules K-1, Partner’s Share
of Income Deductions, Credits, etc.
Further, according to the petition, during 1981 petitioners
were advised by the Internal Revenue Service (IRS) that the
partnership was under investigation and that losses generated by
the partnership might be disallowed. The petition alleges that
for several years petitioners agreed to extend the period of
limitations while IRS investigated the partnership.
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Last modified: May 25, 2011