-2-
versions of the Internal Revenue Code. Dollar amounts are
rounded.
FINDINGS OF FACT1
Some facts were stipulated. The stipulated facts and the
accompanying exhibits are incorporated herein by this reference.
We find the stipulated facts accordingly. Petitioner resided in
New Baltimore, Michigan, when his petition was filed.
In 1992, petitioner married Lisa M. Price (Ms. Price)
(collectively, the Prices). They experienced marital disputes
during 1996, separated in or about 1997, and divorced on November
19, 1998. The Prices were represented by separate legal counsel
during the course of their divorce proceeding.
The Michigan circuit court (circuit court) that presided
over the divorce proceeding entered a judgment of divorce that
ordered and adjudged that the Prices file joint Federal, State,
and local income tax returns for 1992 through 1996. The judgment
also stated that 100 percent of any tax refund as to those years
would go to Ms. Price and, should Mr. Price fail to sign releases
or cooperate in the referenced joint filings, that Ms. Price had
the exclusive right to file those joint returns on their behalf.
1 At trial, petitioner testified in support of his claim for
equitable relief. On the basis of the record as a whole,
including our observation and perception of petitioner when he
testified, we find petitioner’s testimony incredible and decline
to rely upon it to support his position herein. Neonatology
Associates, P.A. v. Commissioner, 115 T.C. 43, 84 (2000), affd.
299 F.3d 221 (3d Cir. 2002).
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