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The issues for decision are: (1) Whether petitioner may
exclude from his income one-half of his wages, Schedule C
insurance business income, interest income, dividend income, and
capital gains distribution pursuant to Texas community property
law; (2) whether petitioner is entitled to Schedule A, C, and E
deductions in amounts greater than those respondent allowed in
the statutory notice of deficiency; (3) whether petitioner is
liable for self-employment tax; (4) whether petitioner is
entitled to dependency exemptions for his two children; (5)
whether petitioner is entitled to file as head of household; and
(6) whether petitioner is liable for an addition to tax for
failure to file a timely return.
FINDINGS OF FACT
Oral stipulations of fact were made at trial.2 The oral
stipulation of facts and the referenced exhibits are incorporated
herein by this reference. Petitioner resided in Dallas, Texas,
at the time he filed his petition.
On May 2, 1987, petitioner married Carol L. Condello (Mrs.
Condello). In 1991, petitioner and Mrs. Condello separated.
During 1992, they were engaged in an acrimonious divorce
proceeding and did not reside together. On March 29, 1994, a
final decree of divorce was rendered.
2 These stipulations were made pursuant to a Rule 91(f)
hearing.
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