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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.
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