- 2 -
Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6654 Sec. 6661
Sec. 6662(a)
1988 $57,984 -0- $40 -0- $14,051 -0-
1989 14,202 $1,445 -0- $922 -0- $2,840
After concessions, the only issues remaining for decision
are: (1) Whether petitioner is entitled to "innocent spouse"
relief from liability for the understatement of tax attributable
to funds his former wife Katy Dawson embezzled during 1988; and
(2) whether funds embezzled by Ms. Dawson during 1989 constitute
community income, one half of which is taxable to petitioner.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91.2 The parties' stipulations are incorporated in this
Memorandum Opinion by reference and are found accordingly.
General Background
At the time of the filing of the petitions herein,
petitioner resided in Orange, Texas.
From September 1972 through January 1982, petitioner was
employed by the U.S. Navy and, from January 1982 through February
1994, was employed by Gulf States Utilities as a power plant
operator and control operations foreman.
2
Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011