Mehran Etesam - Page 2

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               The only issue is whether petitioner is entitled to a joint            
          filing status.                                                              
               The facts may be summarized as follows.  Prior to 1993,                
          petitioner and Maliheh Chasevi (Ms. Chasevi) were married, lived            
          together in Florida, and had filed joint Federal income tax                 
          returns in the previous years.  In April 1993, they separated,              
          and petitioner moved to Georgia.  In late 1993 or early 1994, Ms.           
          Chasevi inquired whether petitioner would file a joint return               
          with her for the 1993 taxable year.  Petitioner agreed, and Ms.             
          Chasevi sent her Form W-2 from her employer to him.                         
               In April 1994, petitioner could not pay the amount due and             
          requested an extension of time for filing the 1993 return.                  
          Sometime later, Ms. Chasevi questioned him about whether a return           
          had been filed.  Petitioner got "upset" but did tell her that he            
          had not filed, and then told her to file her own return.  Ms.               
          Chasevi filed a separate return for the taxable year 1993 in                
          April 1995.  Shortly thereafter petitioner filed a purported                
          joint return for the taxable year 1993.  Ms. Chasevi did not sign           
          the return.  Petitioner signed her name to the return.  Ms.                 
          Chasevi did not know that the purported joint return had been               
          filed until October 1995, and she has not ratified the purported            
          joint return in any fashion.                                                
               Upon examination of the purported joint return filed by                
          petitioner, respondent disallowed the dependency exemption                  
          claimed for Ms. Chasevi, removed her income from the gross                  




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