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Mrs. Bartels' death, October 4, 1982, she was a resident of
Rockford, Illinois. At the date of Mr. Bartels' death, May 16,
1989, he was also a resident of Rockford, Illinois.
Sally A. Jouris and Thomas G. Bartels are the duly appointed
executors of both estates. They maintained their legal address
in Rockford, Illinois, at the time the petition was filed.
Mr. and Mrs. Bartels timely filed a joint U.S. individual
income tax return for the 1981 tax year. Following Mrs. Bartels'
death in 1982, Mr. Bartels timely filed a joint U.S. individual
income tax return for the 1982 tax year, pursuant to section
6013(d)(1).2
On March 28, 1990, respondent issued a notice of deficiency
for the 1981 and 1982 tax years. The petition herein in respect
of such notice was timely filed.
Pursuant to a stipulation of settled issues, petitioners
concede liability for the deficiency for the 1981 and 1982 tax
years as determined by respondent.
2 Sec. 6013(d)(1) allows taxpayers to file a joint return
although one spouse dies before the close of the taxable year of
the other.
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