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Mr. Scott timely filed the Scotts’ 1995 return on or before
April 15, 1996. On the 1995 return, the Scotts reported
petitioner’s wages of $9,719, Mr. Scott’s wages of $10,015,
income from his bookkeeping business of $1,460, and his
unemployment compensation of $4,536. Mr. Scott, however, failed
to include the unemployment compensation when computing the total
income. Consequently, the 1995 return reported total income of
$21,194, total tax of $512, income tax withheld of $412, and a
balance due of $100. Mr. Scott did not send a payment for the
balance due with the return. Respondent computed the correct tax
to be $780 and assessed the $100 tax shown on the return plus an
additional $680. The total amount due has not been paid.
Petitioner and Mr. Scott were divorced in January 2001. A
few months before the divorce, Mr. Scott confessed to petitioner
that he had been paying prostitutes during the last 14 years of
their marriage. At the time of the divorce, the Scotts’ youngest
child was still a minor and resided with petitioner. The Scotts
did not own any real property, stocks, or bonds. Pursuant to the
divorce decree, petitioner received most of the furniture and the
car, and she was obligated to pay approximately $8,531 of credit
card debts. Mr. Scott received some furniture and was obligated
to pay listed debts totaling $4,159.40, which included $1,200 of
taxes for tax year 2000. Mr. Scott was also obligated to pay
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