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Petitioner filed separate petitions for each of the notices
of deficiency. At the time the petitions were filed, and during
the years at issue, petitioner's legal residence was Sacramento,
California.
The subject cases did not proceed to trial. The parties
filed separate stipulations of settlement for each docketed case.
For tax year 1988, the parties stipulated that petitioner had a
deficiency in tax of $544 and an addition to tax under section
6653(a)(1) of $27, and no additions to tax under sections
6651(a)(1) and 6661. For tax year 1989, the parties stipulated
that petitioner had a deficiency in tax of $150 and a penalty of
$30 under section 6662(a). No decisions have been entered as a
result of petitioner's motions for administrative and litigation
costs. Rules 231(a)(2)(C), 232(f).
Petitioner is an accountant. In 1975, she married Michael
Sharer (Mr. Sharer), and one child, Derek, was born of the
marriage in 1986. Petitioner's marriage to Mr. Sharer was a
stormy one; however, neither she nor Mr. Sharer filed for divorce
or legal separation. The Court in Sharer v. Commissioner, T.C.
Memo. 1994-453 (involving petitioner's 1986 and 1987 tax years),
found that petitioner and Mr. Sharer were not living together but
were maintaining separate households beginning in early 1986.
The same factual situation existed during 1988 until Mr. Sharer's
death on June 8, 1988.
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