- 3 -
return for 1985; and (7) whether Mrs. London qualifies as a
so-called "innocent spouse".
FINDINGS OF FACT
Some of the facts have been stipulated and are so
found. The stipulation of facts, supplemental stipulation
of facts, and attached exhibits are incorporated herein by
this reference. Petitioners are husband and wife. They
filed a joint Federal income tax return for each of the
years in issue. Respondent issued a separate notice of
deficiency to each petitioner, and each petitioner filed
a petition for redetermination in this Court. The two
cases were consolidated pursuant to Rule 141(a), Tax Court
Rules of Practice and Procedure. In this opinion, all
Rule references are to the Tax Court Rules of Practice
and Procedure. At the time they filed their petitions,
Mr. London resided in Lewisburg, Pennsylvania, and
Mrs. London resided in Weston, Massachusetts. In this
opinion, we sometimes refer to Mr. London as petitioner.
Mr. London graduated from high school in 1957. From
1957 to 1962, he attended Bordentown Military Academy, the
University of Maryland, and Boston University, but he did
not graduate from any of those institutions. Mrs. London
received a bachelor of arts degree from Emmanuel College
where she majored in biology. She also received a teaching
certificate from Salem State College. After graduating
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011