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Tax Returns
Petitioners timely filed their tax returns for 1994, 1995,
and 1996. Petitioners filed a joint return for 1994 and filed
separate returns claiming a filing status of single for 1995 and
1996. Ms. Yeager listed her last name as “Yeager”, and not
“Williams”, on her 1995 and 1996 returns.
Petitioners filed a joint Federal income tax return for
1999. On this return, Ms. Yeager listed her last name as
“Rinehart”.
In January 2001, 1 month prior to the trial in this case,
Mr. Rinehart filed a Form 1040X, Amended U.S. Individual Income
Tax Return, for 1999 changing his filing status from Married
filing joint return to Single. Ms. Yeager also filed an amended
return for 1999 claiming single status. On the amended return,
Ms. Yeager listed her last name as “Yeager”.
OPINION
I. Marital Status
A. Burden of Proof
As a preliminary matter, petitioners argued that respondent
raised a new issue in the answer by asserting that petitioners
should be treated as married for their Federal income tax filing
status, and consequently respondent bears the burden of proof on
the issue of whether petitioners should be treated as married
during the years in issue.
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