-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).Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011