Peter D. Adkison - Page 4




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          other than the tax matters partner of Shavano filed a petition              
          for readjustment with the U.S. District Court for the Northern              
          District of California (District Court case).                               
               On June 9, 2005, petitioner submitted to the IRS a Form                
          8857, Request for Innocent Spouse Relief, seeking relief from               
          joint and several liability on the joint return he filed for the            
          taxable year 1999.  Petitioner requested that the full amount of            
          the tax due for 1999 be allocated in equal shares to him and to             
          Cathleen Adkison pursuant to section 6015(c).  Petitioner has not           
          received a notice of determination from the IRS with regard to              
          his Form 8857.                                                              
               On November 10, 2005, respondent sent a joint notice of                
          deficiency for 1999 to petitioner and Cathleen Adkison.                     
          The deficiency of $5,837,482 set forth in the notice is                     
          attributable to the following adjustments related to the                    
          Adkisons’ participation in Shavano:  (1) The disallowance of a              
          capital loss of $27,213,056; (2) the disallowance of a                      
          partnership loss of $184,822; and (3) a reduction of itemized               
          deductions (investment interest expense) of $812,327.  The notice           
          of deficiency includes an explanation that respondent made a                
          number of alternative determinations including a determination              
          that Shavano was a sham and/or Shavano was formed solely for the            
          purposes of tax avoidance.                                                  








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