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resulting from the sale of her interest in a parcel of property
deeded to petitioner by her former (now deceased) husband, Bert
Walker (Mr. Walker), on her 1997 and 1998 Federal income tax
returns and (2) whether petitioner is liable for accuracy-related
penalties under section 6662(a) for 1997 and 1998.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. All dollar amounts have been rounded to the nearest
dollar.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition in this case was filed, petitioner resided in
Clackamas, Oregon.
Background
Petitioner and Mr. Walker were married on July 16, 1966.
Prior to their marriage, petitioner had worked in several
factories and had obtained a high school equivalent education.
During their marriage, petitioner did not work outside the home.
Mr. Walker worked as a realtor, property developer, and home
builder. Petitioner and Mr. Walker divorced effective
December 20, 1996.
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