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Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. Petitioner's legal residence at the time the petition
was filed was Shreveport, Louisiana.
Petitioner was married to Wayland Wallace (Mr. Wallace)
during 1996. They had two daughters of their marriage.
Petitioner and Mr. Wallace never separated or divorced. He died
on April 27, 1999.
Petitioner and Mr. Wallace were both employed during 1996.
Petitioner's only income that year was wage and salary income of
$7,840. She was employed as an interpreter for the deaf.
Mr. Wallace filed a timely Federal income tax return for
1996. That return included only his income and deductions
related thereto. It did not include petitioner's income, nor did
she sign the return. The return reflected an income tax
liability of $2,299, withholding credits of $3,694, and an
overpayment of $1,395. The IRS applied $35.36 of the overpayment
to an income tax liability of Mr. Wallace for another tax year
and refunded the balance of $1,359.64.
During 1998, petitioner and Mr. Wallace filed an amended
Federal income tax return for 1996. The sole purpose of the
amended return was to elect a filing status of married filing
jointly and to include petitioner's income for 1996, which was
not included on the original return filed by Mr. Wallace. The
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