Sandrus L. Collier - Page 4




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          any, of such tax is attributable to tax withheld from Mr. Col-              
          lier’s wages.                                                               
               At the time of the trial in this case, Ms. Collier was                 
          (1) earning approximately $60,000 a year, (2) enrolled in a                 
          postgraduate program, (3) paying for her adult son’s college                
          education, and (4) caring for her sick mother.                              
               During periods throughout the years 1987-1991, Ms. Collier             
          and Mr. Collier maintained a joint checking account.  At all                
          relevant times, Ms. Collier was responsible for paying at least             
          some of the bills of Mr. Collier and herself.  However, Ms.                 
          Collier did not always have enough money to pay certain of those            
          bills, and a friend (Christine Stotts) lent her undisclosed                 
          amounts of money.                                                           
               At all relevant times, Ms. Collier and Mr. Collier kept                
          information relating to their financial and tax matters in one              
          place, and they both had access to that information.  At times              
          throughout the years 1987-1991, Ms. Collier and Mr. Collier                 
          discussed their financial and tax matters.                                  
               On April 18, 1989, Ms. Collier and Mr. Collier jointly filed           
          Form 1040, U.S. Individual Income Tax Return (Form 1040), for               
          1987 (1987 joint return), which they signed on September 20,                
          1988.  In that return, Ms. Collier and Mr. Collier reported total           
          tax of $6,893 and tax due of $3,926.  At the time Ms. Collier and           
          Mr. Collier filed the 1987 joint return, Ms. Collier did not                
          believe that payment was made of the $3,926 of tax due shown in             





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