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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in St. Henry, Ohio, at the time she filed
the petition in this case.
Petitioner and Carl L. Dues (Mr. Dues), who died on a date
not disclosed by the record before July 9, 2002, jointly filed a
Federal income tax (tax) return for each of the taxable years
1997 (1997 return) and 1998 (1998 return). In the 1997 return,
petitioner and Mr. Dues reported, inter alia, total income of
$80,520, taxable income of $68,320, total tax of $13,775, tax
withheld of $0, and estimated tax payments of $13,889 and claimed
an overpayment of tax of $114 and a refund of tax of $114. In
the 1998 return, petitioner and Mr. Dues reported, inter alia,
total income of $4,155, taxable income of $0, tax withheld of $0,
estimated tax payments of $0, and total tax of $0.
Around April 2000, petitioner and Mr. Dues jointly filed an
amended tax return for each of the taxable years 1997 (amended
1997 return) and 1998 (amended 1998 return). In the amended 1997
return, petitioner and Mr. Dues reported, inter alia, taxable
income of $0, total tax of $0, tax withheld of $0, estimated tax
payments of $13,889, and tax owed of $0. In the amended 1998
return, petitioner and Mr. Dues reported, inter alia, taxable
income of $0, total tax of $0, tax withheld of $0, estimated tax
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