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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition in this case was filed, petitioner resided in
Los Angeles, California.
Petitioner’s Residence(s)
On January 12, 1995, petitioner was divorced from his former
wife, Kathleen Fusaro. During all of 1996, petitioner maintained
a residential address in Hallandale (Hallandale), Broward County,
Florida. While residing in Hallandale, he lived with Kelli Jo
Tackett (Tackett) and their child. Petitioner and Tackett shared
the expenses of the residence, but he paid the majority of the
expenses. Throughout 1996 and through the time of trial in
January 2003, petitioner continued to use his Florida driver’s
license with a Florida address. At the time of trial, petitioner
did not have a permanent California driver’s license.
From April 12 through July 23, 1996, and from August 22
through December 20, 1996, petitioner’s statements from his
personal checking account with First Union Bank showed
petitioner’s address in Hallandale. The statements showed
purchases and withdrawals in both California and Florida
throughout the period covered by the statements, including many
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