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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
References to petitioner are to William D. Barrow.
Background
The parties submitted this case fully stipulated under Rule
122.
A. Petitioners
Petitioners were married during 1983 and 1984 and were
divorced in 1985. Petitioner lived in Niceville, Florida, and
Mrs. Barrow lived in Crestview, Florida, when they filed the
petition in this case.2
Petitioner was an attorney licensed to practice in Florida
in the years in issue.3 He practiced law through the law
partnership of Barrow & Holley. He also participated in several
real estate transactions during the years in issue in a capacity
other than as an attorney.
In 1990, petitioner was convicted of violating 18 U.S.C.
sections 2 and 1956(a)(3)(B) and (C) (laundering drug money) and
2 Petitioners filed joint income tax returns for 1983 and
1984. Petitioner filed his 1985 individual tax return as an
unmarried person. Respondent issued notices of deficiency to
petitioners for 1983 and 1984 and to petitioner for 1985.
Petitioners filed one petition for 1983, 1984, and 1985.
3 Petitioner was not admitted to practice law in Florida at
the time of trial.
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Last modified: May 25, 2011