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6013(e), is entitled to be relieved of tax liability as an
innocent spouse. We hold that she is not.
All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, Ronnie Wilson resided in
Dallas, Texas, and Linda resided in Missouri City, Texas.
Petitioners were married in 1964. During their marriage,
they resided in Plano, Texas. Ronnie is an attorney with a
successful general practice. Linda has an undergraduate degree
in education and taught elementary school while Ronnie was in law
school. After Ronnie completed law school in 1965, Linda stopped
teaching to raise their two children, Michael and Leslie.
In early 1988, petitioners experienced marital problems, and
Ronnie moved out of their house. In July 1988, Ronnie moved back
into their house, and petitioners attempted to reconcile their
differences. These attempts were unsuccessful, and in early 1989
Ronnie and Linda permanently separated.
During the separation period, Ronnie lived in and maintained
an apartment; paid approximately $1,100 a month for the mortgage,
insurance, taxes, and utilities relating to their house; paid
Michael's and Leslie's college expenses; purchased a Jaguar for
himself; and purchased a $23,000 Cadillac for Linda. In
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