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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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