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All section references are to the Internal Revenue Code as in
effect for the year under consideration. All Rule references are
to the Tax Court Rules of Practice and Procedure. All dollar
amounts are rounded.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
Background
Petitioner resided in Cedar Creek, Texas, at the time she
filed her petition.
Petitioner and Mr. Cheshire were married on June 20, 1970;
they permanently separated on July 13, 1993, and were divorced on
December 5, 1994. For 1992, petitioner and Mr. Cheshire
(collectively, the Cheshires) filed a joint Federal income tax
return.
Petitioner received a bachelor of science degree in secondary
education. Upon graduating from college in 1970, she worked
approximately 3 years as an elementary school teacher, then stayed
home for approximately 10 years (1974-84) in order to raise her 2
children. She returned to teaching in 1984.
In September 1985, the Cheshires purchased property located at
24A Simpson Avenue, Cedar Creek, Texas, for use as the family
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