- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011