Michael G. Culver and Christine M. Culver - Page 7




                                        - 7 -                                         
                         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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