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1994 1995
Wages Embezzlement Wages Embezzlement
Michael $27,949 -- $28,234 --
Christine 35,618 $44,152 48,178 $59,128
Total $63,567 $44,152 $76,412 $59,128
On July 7, 1998, Christine was released from prison and
lived for either a month or a month and a half with Michael in
the family residence. Thereafter, but for a week during the
Christmas season of 1998, Christine did not live in the family
residence, and through the time of trial on February 29, 2000,
Christine lived in Portland, Oregon, with another person whom she
met and with whom she had a relationship while in prison.
Christine prepared petitioners' 1994 and 1995 joint Federal
income tax returns, and Michael and Christine both signed and
timely filed the returns. On those returns, Michael’s and
Christine’s wages were accurately reported, but Christine’s
embezzlement income was not reported.
On audit, respondent determined that Christine’s
embezzlement income represented additional unreported taxable
income and that petitioners were jointly liable with respect to
the tax deficiencies relating thereto.
OPINION
Generally, taxpayers filing joint Federal income tax returns
are jointly and severally liable for all taxes due. See sec.
6013(d)(3).
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