- 3 - 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 inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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