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one-half of any assets remaining in the account after payment of
the $52,750); approximately $23,500 from a reserve account held
in the name of Thomas Dillon at Dillon Securities; three
automobiles (a 1978 SC 911 Targa Porsche, a 1981 Ford 250 4 x 4
truck, and a 1985 Chevrolet S-10 Blazer); a 1977 boat and
trailer; and miscellaneous other assets as identified in the
property settlement agreement.
At the time of the dissolution proceedings, petitioner was
aware that the IRS was investigating certain items reported on
petitioner and Thomas Dillon's 1981-1985 Federal income tax
returns. Petitioner negotiated an indemnification clause in the
property settlement agreement to cover any income taxes due for
the years prior to 1987. Pursuant to this clause, Thomas Dillon
is responsible for any income tax liabilities related to the
years prior to 1987.
Petitioner's income has dropped considerably since the
divorce. In her 1994 Federal income tax return, petitioner
reported adjusted gross income of $12,739.
Thomas Dillon's Investments
In 1981, Thomas Dillon invested approximately $150,000 in a
partnership called Supertaps Associates (Supertaps). Supertaps
was a partnership involved with the production and syndication of
two movies, "Superman III" and "Taps". Thomas Dillon sought
investment advice from his accounting firm, Touche Ross & Company
(Touche Ross), prior to investing in Supertaps. The Dillons'
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