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on its face as the date of entry for the judgment "_____ day of
December, 1992".
On February 4, 1993, the written divorce decree was entered
by the judge. On the written decree, the judge crossed out "____
day of December, 1992", and wrote in "4th day of February, 1993".
On petitioner's 1991 Federal income tax return, the $37,767
bonus that petitioner received from Dean Witter in 1991 was
reported as taxable wages. Petitioner also claimed $76,243 in
itemized deductions, including $5,433 as an investment interest
expense. Despite large deductions claimed on petitioner's 1991
Federal income tax return, no calculation of an alternative
minimum tax was reflected on the return.
Petitioner timely requested an automatic extension to file
his 1991 Federal income tax return, but petitioner failed to
properly estimate and make a payment of tax with the extension
request. On August 14, 1992, petitioner filed his 1991 Federal
income tax return as a married person filing separately from his
spouse.
On August 18, 1993, petitioner timely filed a 1992 Federal
income tax return. On his 1992 Federal income tax return,
petitioner claimed, among other things, that his filing status
was "single", and petitioner claimed $31,796 in deductions, as
indicated in the schedule below:
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