Ruthe G. Ohrman - Page 12

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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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