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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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