- 3 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and attached exhibits are incorporated herein. At the time the petition was filed, petitioner resided in Ozona, Florida. Petitioner and his former spouse2 were husband and wife throughout the years at issue. They filed joint Federal individual income tax returns for taxable years 1980, 1981, 1982, 1983, 1984, and 1985. Despite being married, petitioner filed his 1986 Federal individual income tax return using the filing status of "head of household." Petitioner was a practicing dentist throughout the years at issue. During that period, both he and his former spouse were co-owners of a foreign bank account (the foreign account) located in the Bahamas. From time to time, petitioner opened subsidiary accounts within the foreign account for various investment purposes. Neither petitioner nor his former spouse made withdrawals from the foreign account prior to 1986.3 On September 1986, petitioner opened a second foreign account with the same Bahamian bank. Unlike the first foreign account, 2Petitioner's former spouse, Fern M. Polidori, is not a party in this case. 3The parties have stipulated that neither petitioner nor his former spouse withdrew funds from the foreign account prior to 1986. The account records, however, indicate that at least one cash withdrawal was made on September 29, 1981, in the amount of $300.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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