- 2 - 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. OnPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011