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Whether petitioner was the sole owner of a residence for Federal
income tax purposes and, thus, required to recognize 100 percent
of the gain on its disposition; and (2) whether petitioner is
liable for the accuracy-related penalty for substantial
understatement of income tax.
FINDINGS OF FACT
S. Victoria Wells (petitioner) resided in Balboa Island,
California, at the time her petition in this case was filed. On
August 25, 1968, petitioner married Thomas F. Wells (Mr. Wells)
in the State of California. On May 28, 1987, petitioner and Mr.
Wells separated. On August 6, 1987, petitioner commenced a
proceeding for divorce in the Superior Court of the State of
California for Orange County (Superior Court). A divorce decree
was filed on May 17, 1990, dissolving the marriage. The Superior
Court retained jurisdiction to decide child custody and division
of marital property issues, and its judgment was filed on June
12, 1991.
While petitioner was married to Mr. Wells, they purchased,
as joint tenants, a residence located at 10902 Paddock Lane,
Santa Ana, California (Paddock Lane property). Their property
deed was recorded on April 25, 1978. From April 25, 1978, until
May 28, 1987, when petitioner and Mr. Wells separated, the
property was their primary residence. Petitioner continued to
reside there after the separation from Mr. Wells.
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