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Petitioners resided in Nassau, New York, when they filed their
petition.
FINDINGS OF FACT
During 1987 and 1988, petitioner Raymond P. Corkrey
(petitioner) and his former wife Gunn Corkrey (petitioner's ex-
wife) were estranged. They divorced in 1990. Petitioner failed
to file timely Forms 1040 for the years 1987 and 1988.
Petitioner's gross income for each of the years 1987 and 1988
exceeded the filing requirements. On May 12, 1991, petitioner
married his present wife, Megan B. Flom-Corkrey (petitioner's
wife).
The Andover Service Center's (Center) record of wages earned
by petitioner during 1987 showed that he earned wage income of
$35,100 from Burnt Hills-Ballston Lake Central School District
for teaching a scuba diving course. The Center's record of
petitioner's wages was based upon information received from the
Social Security Administration (SSA). Employers send Form W-2
information for each employee to the SSA along with copies to the
individual employee, indicating the employee's total wages,
income tax withholding, and Social Security taxes withheld for
1(...continued)
the Taxpayer Bill of Rights 2 (TBOR 2), Pub. L. 104-168, secs.
701-704, 110 Stat. 1452, 1463-1464 (1996), which is effective
with respect to proceedings commenced after July 30, 1996. See
TBOR 2 secs. 701(d), 702(b), 703(b), and 704(b), 110 Stat.
1463-1464. Unless otherwise indicated, all Rule references are
to the Tax Court Rules of Practice and Procedure.
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