2
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
FINDINGS OF FACT
Some of the facts are stipulated and are so found. We
incorporate by reference the stipulation of facts and attached
exhibits.
Petitioner resided in Champaign, Illinois, when she filed
the petition in this case. Petitioner married William S. Vriner
(Mr. Vriner) in 1980, and they obtained a divorce in 1993. From
1984 through 1987, petitioner and Mr. Vriner (the Vriners) filed
joint Federal income tax returns, and they reported no taxable
income during those years. The Vriners lived in a house acquired
by Mr. Vriner prior to their marriage. The home was located in
an older neighborhood with moderate- to low-priced homes. They
received residential services including telephone, cable TV,
garbage pickup, water, and electricity. During 1987, petitioner
had credit accounts with Amoco Oil Co., J.C. Penney, and
Bergners, and a Visa account with Chemical Bank.
Mr. Vriner, along with his parents and siblings, worked at a
restaurant owned by his parents (the Vriner restaurant). When
they first met, Mr. Vriner told petitioner that he worked at the
Vriner restaurant for a living, and he later told her that the
arrangement between him and his family's restaurant was none of
her business. Petitioner never saw a paycheck of Mr. Vriner's
from the restaurant, but she assumed that he was being paid. Mr.
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