Marianne Hopkins v. Commissioner

120 T.C. No. 17

UNITED STATES TAX COURT MARIANNE HOPKINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 363-01. Filed June 30, 2003. 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…