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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).
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