- 3 -
Petitioner and Emmens were divorced in 1994. However,
petitioner had not lived with Emmens since May 1988, when he was
arrested for narcotics violations. Emmens has been incarcerated
since that time and is currently serving a 17-year sentence at
the Federal penitentiary in Jesup, Georgia.
Legitimate Business Activities
From 1978 until December 1984, petitioner owned and operated
the Lake Clarke Beauty Salon (the beauty salon) through a
partnership with her first husband, Bobby Buckner. In 1982,
1983, and 1984, the beauty salon reported net income of $4,944,
$8,448, and $838, respectively. Petitioner received a 50-percent
distribution of such amounts. Petitioner managed the beauty
salon on her own after separating from her first husband and
continued to do so after she married Emmens. Petitioner kept
records for the beauty salon and ensured that tax returns for the
business were filed.
During the years in issue, Emmens was a self-employed
locksmith. Emmens operated the business as a sole proprietorship
in 1981 and 1982, and incorporated the business as Nelson
Locksmith, Inc. (Nelson Locksmith or the corporation) in 1983.
In 1982, Nelson Locksmith generated a $8,276 net loss, reflected
on the joint return filed by petitioner and Emmens. In 1983,
Emmens reported $1,200 in wages from Nelson Locksmith.
Petitioner and Emmens owned the building in which Nelson
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011