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joint return, i.e., $13,643, takes into account the section 1 tax
applicable to the taxable income reported on the joint return and
the section 1401 tax (self-employment tax) applicable to the net
profit reported on the Schedule C. Against this amount, Federal
income tax withholdings, as reported on the above-mentioned Forms
W-2, are applied, resulting in an amount due of $5,768, none of
which was paid with the joint return.
Petitioner neither reviewed nor signed the joint return.
She did not authorize Mr. Stimeling to sign this or any other
Federal income tax return on her behalf.
Toward the end of 1993 or the beginning of 1994, petitioner
learned that respondent was attempting to garnish the wages of
Mr. Stimeling in order to collect the then-outstanding 1992
Federal income tax liability. In order to avoid having her own
wages garnished (and to avoid the attendant embarrassment in her
workplace), she entered into an installment agreement with
respondent with respect to that liability. She made the
following payments in accordance with that installment agreement:
Date Payment
January 27, 1994 $175
February 7, 1994 175
February 25, 1994 175
March 29, 1994 175
April 28, 1994 175
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