Patricia Barranco - Page 2




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                                  FINDINGS OF FACT                                    
          The parties have stipulated some facts, which we incorporate                
          herein by this reference.  When she petitioned this Court,                  
          petitioner resided in Blacksburg, Virginia, with her husband, Dr.           
          Salvatore D. Barranco (Dr. Barranco).                                       
          I.   Personal History/Household Management                                  
          Petitioner and Dr. Barranco were married during all the                     
          years at issue, as well as up through the trial of this case.               
          They have three daughters and a son.                                        
               When petitioner married Dr. Barranco in 1961, she was in her           
          second year of nursing school; he was in medical school.  Since             
          getting married, she has not received other formal education or             
          gainfully worked outside the home.                                          
               During the years at issue, Dr. Barranco was a financially              
          successful orthopedic surgeon in private practice in Blacksburg,            
          Virginia.  In 1983, he was a 50-percent shareholder of the                  
          medical practice corporation in which he practiced.  During the             
          remaining years at issue, he was the sole shareholder of the                
          corporation.  Petitioner was not involved in Dr. Barranco’s                 
          medical practice, and he did not usually discuss it with her.               




               1(...continued)                                                        
          otherwise indicated, all other section references are to the                
          Internal Revenue Code in effect for the years at issue and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  




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