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section 6651(a)(2) for 1996; and (7) whether Mr. Meyer is liable
for an addition to tax pursuant to section 6654(a) for 1994,
1995, and 1996.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, Mr. Meyer resided in New York, New York. As of the
time of trial, Mr. Meyer was 37 years old.
In 1987, Mr. Meyer married Patricia Meyer (Ms. Meyer) in San
Francisco, California. In 1989, Mr. Meyer and Ms. Meyer moved to
Hawaii. In July 1990, Ms. Meyer gave birth to the couple’s only
child Richard J. Meyer IV (Richard).
Between February and May 1993, Mr. Meyer, Ms. Meyer, and
Richard moved to Seattle, Washington. In May 1993, Mr. Meyer and
Ms. Meyer separated. Mr. Meyer and Ms. Meyer did not enter into
a formal separation agreement.
After separating, Ms. Meyer and Richard moved back to Hawaii
and lived in Ms. Meyer’s parents’ condominium. During the years
in issue, Richard resided in Hawaii with Ms. Meyer.
After separating, Ms. Meyer did not work. During the years
in issue, Ms. Meyer was unemployed. Ms. Meyer did not pay
rent, utilities, or any other expenses associated with living in
her parents’ condominium.
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