Thus, when Mr. Woodward requested that petitioner sign the income
tax returns and application for refund, she did so without
examining them and without hesitation.
Mr. Woodward died in 1991. Petitioner was the sole
beneficiary of his estate.
During their marriage, petitioner and Mr. Woodward did not
live extravagantly, nor did their standard of living vary
dramatically over the course of their marriage. In 1983
petitioners sold their home and rented an apartment. Petitioners
did not purchase any "big ticket" items in 1983, 1984 or 1985.
At some point in 1983 or 1984, petitioners leased a Chevrolet
Nova automobile.
2. The Income Tax Returns
On their joint income tax returns for 1980 through 1983,
petitioner and Mr. Woodward reported total income and income tax
as follows:
Year Total income Income tax
1980 $48,585.21 1$10,180
1981 47,598.00 29,620
1982 47,388.00 35,233
1983 1,568.00 ---
1 Without regard to the claimed investment credit carryback from
1983 in the amount of $10,180.
2 Without regard to the claimed investment credit carryback from
1983 in the amount of $9,620.
3 Without regard to the claimed investment credit carryback from
1983 in the amount of $700.
a. 1983 Return
Petitioner and Mr. Woodward attached a Schedule C to their
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