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against petitioner of $13,599 for 1984 and $11,358 for 1985. In
determining the deficiencies for the taxable years in issue,
respondent made adjustments for the following items: Unreported
rental income, embezzlement income, and improper real estate tax
and mortgage interest deductions.
Background
Petitioner was raised in a poor neighborhood in Memphis,
Tennessee, in a low-income family. At the age of 16, she married
her first husband, Charles Edward McCulley (McCulley). The next
year petitioner became pregnant and dropped out of high school.
Petitioner's daughter and son were born in June of 1973, and July
of 1975, respectively. In October of 1977, petitioner and
McCulley were divorced.
In 1983, petitioner completed the requirements for a general
equivalency diploma (GED), the highest degree she has attained.
In 1984, petitioner took courses as a non-matriculated student at
Memphis State University for which she received an A, a B, and
two failing grades. Petitioner has had no education or training
in business or tax matters.
During the years in issue, petitioner became involved in a
relationship with Byron Kelly Griffith (Griffith), a man she
married in 1985. Griffith physically, mentally, and emotionally
abused petitioner. During their separation a neighbor once
called police, who arrested Griffith when they caught him choking
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