Sybil M. Smith - Page 2




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          joint return for that year.  Unless otherwise indicated, all                
          section references are to the Internal Revenue Code in effect for           
          the years in issue, and all Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Albertville, Alabama, at the time that she            
          filed the petition.  From July 13, 1968, until March 8, 1995,               
          petitioner was married to H. Smith.  H. Smith was a lawyer.                 
               On October 17, 1988, petitioner and H. Smith filed a joint             
          Federal income tax return for 1987 on which they reported a tax             
          liability of $63,776.  No part of that liability was paid at the            
          time of filing of the return.  Audit of the 1987 return commenced           
          in January 1989.                                                            
               During 1992, petitioner was employed at Bullock County                 
          Hospital as a nurse.  On August 27, 1993, petitioner and H. Smith           
          filed a joint Federal income tax return for 1992 on which they              
          reported a tax liability of $3,107.  No payments were made or               
          credited at the time of filing of the 1992 return.  On                      
          September 20, 1993, assessments were made for the tax reported on           
          the return, of $69 for an estimated tax penalty, $93.21 for a               
          failure to pay penalty, and $95.58 for accrued interest.                    
          Collection costs of $11 were assessed on December 27, 1993.  On             






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