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penalties under section 6662(b)(2) for the taxable years 1989 and
1990; and (5) whether Irene is liable for additions to tax under
section 6651(a)(1) and section 6661(a) for the taxable year 1988
and penalties under section 6662(a) for the taxable years 1989
and 1990.
Background
These cases were submitted to the Court fully stipulated.
The stipulation of facts and the exhibits attached thereto are
incorporated by this reference.
Edward was a resident of Elburn, Illinois, at the time of
filing his petition. Irene was a resident of Barrington,
Illinois, at the time of filing her petition.
Petitioners were married on June 15, 1963. Petitioners
initially separated in February 1980 but continued to live
together on an irregular basis at the marital residence prior to
March 17, 1983.
Petitioners entered into a separation agreement on March 17,
1983. Pursuant to this agreement, Edward transferred to Irene
his entire interest in their marital residence located in
Barrington, Illinois. Pursuant to the agreement, Edward also
paid Irene from $10,000 to $10,866.67 per month in addition to
certain of her expenses from April 1983 until December 1988.
On November 23, 1987, Edward sued Irene in the Circuit Court
of Cook County, Illinois, County Department-Domestic Relations
Division (hereinafter the circuit court), for dissolution of
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