- 6 - 1990, 1991, and 1992, of $39,542, $52,757, and $94,649,4 respectively. To calculate the deficiencies in issue, respondent used rates applicable to married persons filing separately. During 1989 and 1990 petitioner traveled on business to Pennsylvania, Arkansas, Louisiana, and Texas. Sometime around July of 1989, Carolyn Webb went to Texas to care for her terminally ill father. The Webbs returned to California in approximately May of 1990. OPINION Issue 1. Domicile and Allocation of Community Property Income Respondent determined that one half of the income earned by petitioner for 1990, 1991, and 1992 is attributable to Carolyn 4 According to the IRPOLT for 1992, petitioner received $16,050 in rents, which is reflected in the $94,649 amount asserted by respondent against petitioner for 1992. Although respondent failed to include the $16,050 in the notice of deficiency, it was incorporated into the proposed stipulation that was sent to petitioner and deemed admitted pursuant to Rule 91(f)(3).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011