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responsible for paying at least some of the bills of Mr. Collier
and herself, although she did not always have enough money to pay
those bills; (5) during periods throughout 1987-1991 Ms. Collier
and Mr. Collier maintained a joint checking account; (6) at all
relevant times Ms. Collier knew that at least during and before
1987 Mr. Collier had a support obligation with respect to a child
of his that was not Ms. Collier’s child, and during a period
which included at least certain years prior to 1988 Mr. Collier
was in arrears with respect to that support obligation;
(7) sometime after June 12, 1989, and before October 1991,
respondent placed a lien on a joint bank account of Ms. Collier
and Mr. Collier with respect to the unpaid assessment for their
taxable year 1987, and Ms. Collier knew about that lien; (8) Ms.
Collier and Mr. Collier did not pay any tax at the respective
times they filed the joint returns for the taxable years 1987
through 1991; (9) 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 that return; (10) at
the time Ms. Collier and Mr. Collier filed the 1989 joint return
Ms. Collier did not believe that payment was made of the $5,554
of tax due shown in that return; and (11) at the time Ms. Collier
and Mr. Collier filed the 1991 joint return Ms. Collier did not
believe that payment was made of the $8,528 of tax due shown in
that return.
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