Linda Carter Zimmerman - Page 3




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               Respondent determined a $5,740 deficiency in petitioner’s              
          1994 Federal income tax and a $1,435 addition to tax under                  
          section 6651(a)(1) for that year.  The issues for decision are:             
          (1) Whether petitioner’s share of the gain realized from the sale           
          of property jointly owned with her former spouse must be included           
          in her 1994 income, and (2) whether petitioner had reasonable               
          cause for her failure to file a timely 1994 Federal income tax              
          return.                                                                     
          Background                                                                  
               Some of the facts have been stipulated and are so found.               
          At the time the petition was filed, petitioner resided in                   
          Jacksonville, Florida.                                                      
               Petitioner and Richard Edward Zimmerman, Jr. (petitioner’s             
          former spouse), were married in 1972.  They separated prior to              
          or during 1991, and an action for divorce was filed in the                  
          appropriate local court during that year (the divorce                       
          proceeding).  They were divorced by Final Judgment of Dissolution           
          of Marriage, issued on August 14, 1998, by the Circuit Court in             
          Jacksonville, Duval County, Florida (the divorce decree).                   
               In 1979, petitioner and her former spouse purchased a                  
          townhouse in Pensacola, Florida, for $64,832 (the townhouse).               
          Approximately $44,000 of the purchase price was financed.  They             
          took title to the townhouse as tenants by the entireties, and,              
          although the record contains no specific evidence on the point,             






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