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of Law in San Benito, Texas. Petitioner did not pass the Texas
State bar examination.
Petitioner married Amado Robledo (Robledo) in 1981. She
filed for divorce in 1994. Robledo filed a bankruptcy petition
in 1995. The divorce was finalized in 1997. Petitioner was
awarded money and various items of property in the final divorce
decree, including $150,000, three automobiles, and several
parcels of real property. The divorce decree provided in part as
follows:
AMADO ROBLEDO shall be solely responsible for all
federal income tax liabilities of the parties from the
date of marriage through December 31, 1996 and shall
timely pay any deficiencies, assessments, penalties, or
interest due thereon and shall hold Petitioner harmless
therefrom.
IT IS FURTHER ORDERED AND DECREED that the
certificate of deposit in the amount of $200,000.00
plus interest currently held in trust with the Law
Office of Paul L. Wiley * * * in the names of AMADO
ROBLEDO and ANGELA B. ROBLEDO will be used to offset
any tax liabilities, including interest, penalties and
other assessments by the Internal Revenue Service from
the date of marriage through December 31, 1996.
Petitioner and Robledo filed joint Federal income tax
returns for 1989 and 1990. The joint returns reported
underpayments of $6,347 and $271,766 for 1989 and 1990,
respectively. As of the time of trial on September 22, 2003, the
tax, penalty, and interest for 1989 and the tax and interest for
1990 were fully paid after application of payments by Robledo.
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