Donna M. Orsino - Page 2

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          petitioner is entitled to relief from joint and several liability           
          pursuant to section 6015(b), (c), or (f).1                                  
                                  FINDINGS OF FACT                                    
               Petitioner, a legal secretary and high school graduate, and            
          Mr. Orsino, who has a degree in bioengineering, married on                  
          September 1, 1968.  During their marriage, petitioner was                   
          responsible for balancing their joint checking account and paying           
          the monthly bills, and Mr. Orsino was responsible for filing all            
          of their Federal tax returns.                                               
              Mr. Orsino worked for Betz Dearborne as a water treatment              
          specialist for several years prior to, and during, 1998.  He quit           
          his job at Betz Dearborne in April or May 1998, but continued as            
          a consultant for 4 weeks.  Mr. Orsino also performed water                  
          treatment services for National Engineering & Repair Corp.                  
          (National Engineering) in May and June of 1998 and deposited                
          compensation received from both companies in the joint checking             
          account.  Petitioner was aware that Mr. Orsino performed services           
          for both Betz Dearborne and National Engineering.                           
               Petitioner and Mr. Orsino separated sometime in July of                
          1998.  Shortly before their separation, Mr. Orsino’s mother                 
          provided Mr. Orsino with a $6,000 savings bond, which Mr. Orsino            

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  





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