Estate of Mark R. Woodward, Deceased, Lillian H. Woodward, Executrix, and Lillian H. Woodward - Page 3

          for decision is whether petitioner Lillian H. Woodward                      
          (petitioner) qualifies for relief as an innocent spouse under               
          section 6013(e) for the taxable years 1980 and 1981.                        
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners resided in Shaker Heights, Ohio, at the time            
          their petition was filed with the Court.                                    
          1.   General Background                                                     
               Petitioners were married at all relevant times.  From 1980             
          to 1983, petitioners timely filed joint individual Federal income           
          tax returns.                                                                
               Petitioner received a bachelor's degree in history from the            
          University of California at Los Angeles.  Thereafter, petitioner            
          worked for a suburban newspaper for approximately 2 years.                  
          Petitioner then entered the U.S. Coast Guard.  At some point                
          petitioner married Mark R. Woodward and remained married to him             
          until his death in 1991.  Petitioner and Mr. Woodward had three             
          children.  Although petitioner did not work outside the home                
          while she raised her children, she resumed working in 1970 as a             
          customer service representative for the Higbee Company, a                   
          department store in Cleveland, Ohio.  Petitioner worked for the             
          Higbee Co. until 1985.  Her duties as a customer service                    
          representative included tracing deliveries and answering                    
          customers' questions that could not be handled on the floor by a            
          salesperson.  Petitioner earned $14,118.36 in 1983 working as a             
          customer service representative.                                            




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