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