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February 24, 2002. Petitioner and Mr. Ohrman have also continued
to socialize together as a couple since their legal separation.
Petitioner has remained in control of the family finances
since the legal separation and has used Mr. Ohrman’s monthly
support payments to pay her family’s ongoing living expenses,
consisting of the monthly mortgage payment on the Carlton
residence, the utilities, the monthly payment due on her Alaska
Airlines Visa credit card, the house and car insurance premiums,
and groceries for Mr. Ohrman, Alexa, and herself. In addition to
making the monthly support payments to petitioner, Mr. Ohrman
pays at least an additional $1,800 per month for Alexa’s
schooling, his gambling debt, health insurance for petitioner and
Alexa, and life insurance.
Revenue Agent McConnell’s Examination
On December 10, 2001, respondent sent a statutory notice of
deficiency to petitioner and Mr. Ohrman for 1999. In the notice
of deficiency, respondent determined that petitioner and
Mr. Ohrman are liable for a deficiency in income tax of $31,515
and a section 6662(a) accuracy-related penalty in the amount of
$6,303. On March 10, 2002, petitioner timely filed her Petition
for Determination of Relief from Joint and Several Liability on a
Joint Return under section 6015(b), (c), and (f) in response to
the statutory notice of deficiency.
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