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returns, using a tax return preparer to complete the returns. In
1984, petitioner began working for Martin Marietta Electronics
and Missiles Group (Martin Marietta). During 1988 and for part
of 1989, petitioner worked at Martin Marietta as a machine
operator. She earned wages of $12,609 and $2,799 for those
years, respectively.
Mr. Zimmerman operated a sole proprietorship under the name
of Zimmerman's Construction (the business). The business
constructed driveways, sidewalks, and concrete slabs principally
for residential contractors. Mr. Zimmerman learned this trade
through on-the-job experience. The address for the business was
the Zimmermans' home address.
The Zimmermans had a checking account with Security First
Federal Savings and Loan Association (Security) in the name of
"Charles R. Zimmerman or Carla J.M. Zimmerman, DBA Zimmerman's
Construction" (the business account). Petitioner and Mr.
Zimmerman were the authorized signatories on the business
account. Income from the business was deposited into this
account. Business expenses were paid by check from the business
account or sometimes were paid by cash. Petitioner or Mr.
Zimmerman also wrote checks to "Cash" from the business account.
During June and July of 1988, petitioner assisted her
husband by writing the checks for the business. This was during
the time petitioner was at home caring for their newborn
daughter, and, according to petitioner, when the "business really
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