Charol L. Stafford - Page 4

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               Hence, respondent determined that petitioners' total                   
          community property income for each year at issue is as follows:             
                       1989        1990       1991     1992       1993               
          Wage income    $48,854      $52,583$37,569    $53,600  $33,829              
          Pension income          39,073                                             
               Respondent further determined that each petitioner's 50                
          percent share of the above-noted total community property income            
          is as follows:                                                              
                    1989            1990       1991     1992       1993               
          Wage income    $24,427      $26,292$18,785    $26,800  $16,914              
          Pension income           19,537                                             

               Respondent also determined that because Mrs. Stafford filed            
          Federal income tax returns for 1989, 1990, and 1993 reporting the           
          wage income she received in her individual capacity for those               
          years, her respective share of unreported community property                
          income is reduced by the amounts so reported; i.e., $4,090                  
          (1989); $10,875 (1990); and $6,769 (1993).  Thus, respondent                
          determined that Mrs. Stafford's unreported community property               
          income is as follows:                                                       
                    1989            1990       1991     1992       1993               
          Wage income    $20,337      $15,416$18,784    $26,800  $10,145              
          Pension income      19,537                                                  
               When petitioners refused to stipulate any matter proposed by           
          respondent, an order to show cause why such matters should not be           
          deemed stipulated pursuant to Rule 91(f) was issued by the Court.           






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