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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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