Michael J. Downing and Sandra M. Downing - Page 11

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                                         I.                                           
                    The intended husband and wife shall be separate in                
               property, therefore, neither of them shall be liable for the           
               debts contracted by the other, either before or during their           
               marriage;                                                              
                    The intended wife shall have the free and exclusive               
               enjoyment of her separate property, and the full                       
               administration thereof, without the assistance of her                  
               husband.                                                               

                                         II.                                          
                    All property and effects of the said husband and wife,            
               whether owned by him or her at the time of the celebration             
               of said intended marriage, or acquired during said marriage,           
               are hereby declared to be separate property, and that of the           
               wife, separate and paraphernal property, and they and each             
               of them do hereby expressly reserve to themselves                      
               individually the entire administration of their respective             
               particular movable and immovable property, and the                     
               respective free enjoyment of each of their revenues.                   
               On February 2, 2000, the marriage contract was “filed for              
          registry” in the conveyance records of Jefferson Parish,                    
          Louisiana.                                                                  
          D.   The Plumbing Business                                                  
               Michael generally worked alone in the plumbing business.  If           
          he needed help, then he hired independent contractors.  Sandra              
          handled all the bookkeeping for the plumbing business.  She wrote           
          out the invoices and mailed them to customers, paid the bills,              
          organized the records, did the banking, and submitted figures to            
          petitioners’ C.P.A. for use in preparing petitioners’ tax                   
          returns.  The plumbing business was on the cash basis for 1994              
          and 1995.  Sandra computed gross income for the years in issue by           





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