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For taxable years 1992 through 1996, Mr. Kean and Ms. Kean
were not legally separated under a decree of divorce or separate
maintenance.
Pursuant to court orders, the payments made by Mr. Kean to
Ms. Kean during the period of April 7, 1992, through February
1995, were deposited into the joint checking account. Pursuant
to court order, during the period of March 6, 1995, through
December 1996, Mr. Kean made payments to the account of Ms. Kean
with the Somerset County Probation Department. The checks
received by Ms. Kean from the Somerset County Probation
Department were deposited by her into the joint checking account.
From at least March 5, 1993, through December 1996, Mr. Kean
did not make any withdrawals or write any checks on the joint
checking account.
Ms. Kean filed her U.S. Individual Income Tax Return for
1992 late on June 8, 1998. Ms. Kean filed her U.S. Individual
Income Tax Return for 1993 on January 22, 1996. Respondent did
not determine a penalty for failure timely to file an income tax
return for 1993. Ms. Kean filed her U.S. Individual Income Tax
Return for 1994 late on January 29, 1996. Ms. Kean filed her
U.S. Individual Income Tax Return for 1995 on October 11, 1996.
Her 1995 return was filed within a permitted extension of time to
file. Ms. Kean timely filed her U.S. Individual Income Tax
Return for 1996 on April 15, 1997.
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