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petitioners may file a joint return after filing separate returns
for the 1997 tax year; and (5) whether petitioners are liable for
the accuracy-related penalty under section 6662(a) for 1995,
1996, and 1997.
Background
The stipulation of facts and the accompanying exhibits are
incorporated herein by reference. Petitioners resided in
Virginia Beach, Virginia, at the time their petition was filed
with the Court.
Petitioners are a married couple who filed joint Federal
income tax returns for tax years 1995 and 1996. Petitioners,
however, filed 1997 returns separately. Petitioner Patricia
Favero’s (Mrs. Favero) 1997 return is not in issue in this case.
Since December 31, 1994, petitioners have been citizens and
residents of the United States.
During the years in issue, Mr. Favero was employed by U.S.
corporations and/or businesses as a sailor on board merchant
ships. He was a member of the Seafarers International Union
(SIU) and received his ship assignments from the union hall
located in Norfolk, Virginia. The headquarters of SIU is located
in Camp Springs, Maryland. Mr. Favero has not filed any tax
returns for any tax period since December 31, 1994, with any
foreign country, nor has he paid tax to any foreign country.
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Last modified: May 25, 2011