Alfred J. Martin - Page 3




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                                  FINDINGS OF FACT                                    
               Some of the facts are stipulated and are so found.                     
          A.   Petitioners                                                            
               Petitioner lived in Suffolk, Virginia, on August 4, 1986,              
          when the petition for tax years 1981 and 1982 (docket No. 32146-            
          86) was filed.  When the petition was filed for tax year 1980 in            
          docket No. 22961-88, on September 6, 1988, petitioner lived in              
          Suffolk, Virginia, and petitioner Amilu S. Rothhammer                       
          (Rothhammer), formerly Amilu S. Martin, lived in Colorado                   
          Springs, Colorado.                                                          
               Petitioners are both medical doctors.  In 1980, petitioner             
          and Rothhammer were married to each other and were practicing               
          medicine in Colorado Springs, Colorado.  Steven Covalt (Covalt),            
          a certified public accountant, prepared their joint 1980 Federal            
          income tax return.  Covalt was petitioner’s and Rothhammer’s                
          accountant from 1972 until 1981 and was petitioner’s accountant             
          until 1986.  On November 1, 1981, petitioner signed a Form 2848,            
          Power of Attorney, in which he authorized Covalt to represent him           
          before the Internal Revenue Service (IRS).                                  
               Petitioner and Rothhammer were divorced in 1981 and have not           
          had any direct contact with each other since then.  Any indirect            
          contact between them has been through counsel.  In the divorce              
          settlement, petitioner and Rothhammer agreed to share equally any           
          income tax liability for 1980.                                              
               In June 1982, petitioner reentered the Navy as a captain in            




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