Pamela Renee Wiggins - Page 4

                                        - 3 -                                         
                               Wages         Federal Income Tax W/H                   
          Petitioner          $23,708             $3,001                              
          Mr. Stimeling       34,707              5,078                               

          During 1992, Mr. Stimeling was also the sole proprietor of S&S              
          Repairs, a business that provided janitorial and repair services.           
               Mr. Stimeling asked petitioner if she would agree to file a            
          joint 1992 Federal income tax return, even though they were                 
          separated at the time and soon to be divorced.  Petitioner                  
          agreed, expecting to see and sign the return after it had been              
          prepared and before it was mailed to be filed.  In prior years              
          (presumably 1990 and 1991), petitioner filed joint Federal income           
          tax returns with Mr. Stimeling.  For each of those years the                
          return was prepared by a paid income tax return preparer,                   
          reviewed by petitioner, and signed by petitioner.                           
               The same paid income tax return preparer that had prepared             
          petitioner’s returns for previous years prepared what purports to           
          be a joint 1992 Federal income tax return for petitioner and Mr.            
          Stimeling (the joint return).  The joint return was received,               
          timely filed, and processed by respondent.  The income reported             
          on the joint return consists of the wages reported on the above-            
          mentioned Forms W-2 and the net profit reported on a Schedule C,            
          Profit or Loss From Business, for S&S Repairs.  Taxable income              
          reported on the joint return is computed taking into account                
          itemized deductions.  The “total tax” liability reported on the             





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