Carolyn Webb - Page 7

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          Webb.5  Carolyn Webb asserts that she was not a resident of                 
          California during 1989 and part of 1990, and therefore is not               



























          5    For the taxable years in issue, respondent issued two                  
          notices of deficiency, one in petitioner's name and one in the              
          name of Carolyn Webb.  In the notice of deficiency asserted                 
          against petitioner, respondent determined that 100 percent of the           
          earned and unearned income in petitioner's name was attributable            
          to him.  In the notice of deficiency asserted against Carolyn               
          Webb, respondent determined that for 1990 and 1991, 50 percent of           
          the earned and unearned income in petitioner's name was                     
          attributable to her.  However, for 1992, the notice of deficiency           
          attributes only $27,038 of petitioner's income to Carolyn Webb.             
          See supra note 3.  For the years 1990, 1991, and 1992, respondent           
          concedes the income asserted against petitioner to the extent               
          that his income is reattributed to Carolyn Webb according to                
          California community property law.                                          



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