Patricia A. Hendricks and John J. Hendricks - Page 17

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          understatement of tax or that further investigation was                     
          warranted.  Petitioner has satisfied the section 6015(b)(1)(C)              
               The final question is whether, taking into account all the             
          facts and circumstances, it would be inequitable to hold                    
          petitioner liable for the deficiency attributable to the                    
          understatement on the joint 1983 tax return.  Sec. 6015(b)(1)(D).           
               Respondent argues that it would not be inequitable for                 
          petitioner to be held liable for the understatement on the joint            
          1983 tax return because title to the remaining condominiums was             
          transferred in 1997 to her name alone.  The Hendrickses acquired            
          the condominiums before Mr. Hendricks invested in Boulder Oil and           
          Gas.  The condominiums were acquired by exchanging other property           
          the Hendrickses had previously owned and were not acquired from             
          proceeds made available through the investment in Boulder Oil and           
          Gas.  Mr. Hendricks transferred his joint interest in the                   
          remaining condominiums to petitioner nearly 3 years before                  
          respondent assessed the deficiency for 1983 and began collection            
          action against the Hendrickses for that tax year.  The                      
          Hendrickses had paid the balances due for 1980-82 with moneys,              
          derived in part, from the sale of several of the condominiums,              
          and the Hendrickses mistakenly believed that they had settled the           
          1983 tax year and did not owe any more tax liabilities.                     

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