Legal Opinion

Hopkins v. Comm'r

United States Tax Court

Decided June 30, 2003No. 363-01Published

P filed a request for relief under sec. 6015, I.R.C., with respect to her joint and several tax liabilities for 1982 and 1983. P and H reported loss deductions from a partnership on their returns for those years. In 1988, P and H signed a closing agreement under sec. 7121, I.R.C., in which they agreed to adjustments with respect to the partnership deductions. The adjustments to the partnership deductions resulted in tax deficiencies for 1982 and 1983, which R assessed.

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P filed a request for relief under sec. 6015, I.R.C., with respect to her joint and several tax liabilities for 1982 and 1983. P and H reported loss deductions from a partnership on their returns for those years. In 1988, P and H signed a closing agreement under sec. 7121, I.R.C., in which they agreed to adjustments with respect to the partnership deductions. The adjustments to the partnership deductions resulted in tax deficiencies for 1982 and 1983, which R assessed. The tax liabilities for those years were the subject of a prior bankruptcy case involving P and H and the Government. In that…

1Opinion of the Court

MARIANNE HOPKINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hopkins v. Comm'r

No. 363-01

United States Tax Court

120 T.C. 451; 2003 U.S. Tax Ct. LEXIS 19; 120 T.C. No. 17;

June 30, 2003, Filed

Petitioner was not precluded by closing agreement or doctrines of res judicata and collateral estoppel from claiming relief under section 6015 with respect to liabilities attributable to Far West Drilling partnership.

P filed a request for relief under sec. 6015, I.R.C., with

respect to her joint and several tax liabilities for 1982 and

1983. P and H reported loss deductions from a partnership on

2Cases cited18 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Zaentz v. CommissionerUnited States Tax Court · 1988
  3. Cheshire v. CommissionerUnited States Tax Court · 2000
  4. Kathryn Cheshire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2002
  5. Meier v. CommissionerUnited States Tax Court · 1988

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