Carolyn Webb - Page 6

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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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