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tioner knew about the July 15, 1994 accident as well as the
injuries that Mr. Mellen suffered and the damage or destruction
to his property caused by that accident.
In a letter dated June 10, 1997, the Social Security Admin-
istration (SSA) determined that Mr. Mellen was disabled, that his
disability arose as of October 30, 1996, and that he satisfied
the medical requirements for Social Security disability benefits
(SS disability benefits). Sometime after June 10, 1997, the SSA
determined that Mr. Mellen satisfied the nonmedical requirements
for SS disability benefits and that he was entitled to such
benefits as of April 1997. At a time not disclosed by the
record, the SSA also determined that Mr. Mellen was entitled to
hospital insurance under Medicare as of April 1999.
From at least March 1999 to the time of the trial in this
case, Mr. Mellen received monthly SS disability benefits that
ranged from approximately $900 to $949.
At times that are not disclosed by the record, petitioner
and Mr. Mellen jointly filed Form 1040, U.S. Individual Income
Tax Return (return), for each of the taxable years 1986 through
1991.
Sometime after October 15, 1996, but before October 23,
1996, petitioner and Mr. Mellen jointly filed a return for each
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