- 3 - 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 (reliefPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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