Joseph T. Walker and Nancy Walker - Page 3

                                     - 3 -                                            
     that were involved in overbilling and kickback arrangements with Mr.             
     Walker and petitioner West Jersey Manufacturing Co., Inc.(West                   
     Jersey); (2) whether Mr. Walker and petitioner Nancy Walker (Mrs.                
     Walker) filed joint individual income tax returns for 1978, 1979,                
     1980, and 1981; and (3) whether Mrs. Walker is entitled to relief for            
     any tax liabilities determined with respect to her for 1978, 1979,               
     1980, and 1981, as an innocent spouse under section 6013(e).2                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found. The           
     stipulations of facts and attached exhibits are incorporated by this             
     reference.                                                                       
               At the time their petition was filed, Mr. Walker and Mrs.              
     Walker resided in Stone Harbor, New Jersey. They were married in June            
     1963. From June 1963 through the time of the trial in the instant                
     cases, Mr. Walker and Mrs. Walker have been married to one another and           
     have resided together. Mr. Walker filed with the Internal Revenue                
     Service (IRS), for each of the years 1978, 1979, 1980, and 1981, a               
     Form 1040, Individual Income Tax Return, which was stated to be the              
     joint individual income tax return of himself and Mrs. Walker.                   
     Although Mr. Walker signed his own name to each of the returns, he did           
     not have Mrs. Walker execute the returns. Mr. Walker or another                  
     individual, acting at Mr. Walker's direction, subscribed Mrs. Walker's           


               2All section references are to the Internal Revenue Code as            
          in effect for the years in issue. All Rule references are to the            
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011