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Betty Drummond received wage income of $27,115.37 during
1983, which was community property, one-half of which is
includible in Mr. Drummond's income for 1983.
During 1984, Mr. Drummond and Ms. Drummond had a joint
Merrill Lynch account from which they received interest income
during that year in the amount of $2,899, one-half of which is
interest income to each of them for that year. During that year,
Mr. Drummond also received interest income in the amount of $241
from the Bank of San Diego.
Betty Drummond filed for divorce from Mr. Drummond in 1984.
On October 5, 1984, a bifurcated judgment of dissolution of the
marriage of Mr. Drummond and Betty Drummond was issued. On July
16, 1985, a final judgment of dissolution of that marriage was
entered. Pursuant to the property settlement agreement incident
to that divorce, Betty Drummond was awarded $21,890 of precious
metals.
Mr. Drummond, who has knowledge of tax matters and was
capable of correctly preparing and filing his own returns for
1983 and 1984, prepared his returns for those years and filed
them around September 19 and October 17, 1985, respectively. Mr.
Drummond reported gross receipts in Schedule C of his 1983 return
in the amount of $70,020. Those gross receipts consisted of
$42,000 that Mr. Drummond received from ABC and $28,020 that he
received from other clients during 1983. Mr. Drummond did not
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