- 6 -
and Financial Research Services went out of business some time in
late 1997 or early 1998. Despite the loss of his mortgage broker
license, Mr. Barrera was able to work with Federal Housing
Administration “Title I” home improvement loans, and, in 1998, he
continued this activity in a new business venture called Tropical
Funding.
In December 1997, petitioner and Mr. Barrera untimely filed
their joint return for taxable year 1996. The 1996 joint return
reported adjusted gross income of $149,446, and tax due of
$27,389, which amount was paid by petitioner and Mr. Barrera.
After the closure of Financial Research Services,
petitioner’s lifestyle began to change, and from 1998 onwards,
she and her family were living less comfortably. Throughout 1998
and 1999, Mr. Barrera was paying living expenses and family bills
with credit cards or early distributions from his individual
retirement account (IRA), though he did not tell petitioner he
was doing this. Mr. Barrera ran the household the same way, and
petitioner never asked Mr. Barrera about money during this time,
as she continued to feel it was “just not * * * [her] concern.”
At some point in 1998, respondent began an examination that
included petitioner and Mr. Barrera’s joint Federal income tax
returns for taxable years 1995 and 1996. As a result of this
exam, petitioner and Mr. Barrera agreed to respondent’s
determination of a deficiency for taxable year 1995 in the amount
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007