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Petitioner resided in Arden, North Carolina, at the time the
petition was filed.
Sometime in January 1990, petitioner withdrew $37,095.52
from an annuity contract that he had with Metropolitan Life
Insurance Company (1990 annuity withdrawal). The joint Federal
income tax (tax) return for 1990 (1990 joint return) filed by
petitioner and his then spouse, who is now known as Florencie G.
Bacon (Ms. Bacon), failed to include as income $14,758 of the
1990 annuity withdrawal.
Petitioner and Ms. Bacon divorced sometime after they filed
the 1990 joint return. On January 8, 1992, in connection with
their divorce, petitioner and Ms. Bacon executed an agreement in
which they agreed, inter alia, to be jointly responsible for any
additional taxes determined by respondent to be due for 1990 with
respect to any annuity contracts held by petitioner.
At a time not disclosed by the record, respondent determined
a deficiency of $5,691 for taxable year 1990 (1990 tax defi-
ciency) against petitioner and Ms. Bacon. The 1990 tax defi-
ciency was attributable solely to the failure of the 1990 joint
return to include as income $14,758 of the 1990 annuity with-
drawal. Respondent did not determine any penalties against
petitioner and Ms. Bacon for 1990.
Sometime prior to October 1993, Ms. Bacon requested respon-
dent to grant her relief from joint and several liability (relief
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