S. Victoria Wells - Page 2

                                        - 2 -                                         

          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.                           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011