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Petitioner did not file a Federal income tax return for any
of the years in issue, nor did petitioner pay estimated tax for
any of those years.
B. Facts Relating to the Setoff of Alleged Overpayments for
Prior Years
Petitioner and his ex-wife separated in 1983 and were
divorced in 1985. By virtue of the separation and divorce,
petitioner became obligated to pay child support.
1. Petitioner’s Testimony
At trial, petitioner testified that from 1983 through early
1988, he paid child support directly to his ex-wife by personal
and certified check; that in December 1987, his ex-wife filed a
complaint against him with the Iowa State support enforcement
office for nonpayment of child support; and that his ex-wife’s
complaint was completely unfounded. According to petitioner, the
support enforcement office would not “recognize the payments”
that he had made by check, and that, as a consequence, the
enforcement office improperly commenced collection action against
him.
The collection action to which petitioner alludes was
described by him at trial as follows:
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