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In 1966, petitioner married Mr. Barnes, who is the younger
brother of David Barnes, when both petitioner and Mr. Barnes were
approximately 21 years old. Mr. Barnes then received an
undergraduate degree in personnel management from Sacramento
State College in 1969. In 1981, Mr. Barnes was employed by the
State of California as a personnel analyst. During the years of
their marriage, petitioner and Mr. Barnes always discussed major
decisions, such as purchasing a house, car, and other large
expenditures. Prior to their separation in 1982, Mr. Barnes and
petitioner maintained a joint checking account. They both
deposited their paychecks into this account, and petitioner
generally was responsible for paying the household bills from it.
Petitioner and Mr. Barnes filed joint Federal income tax returns
from 1966 through at least 1984. In the years 1978, 1979, 1980,
and 1981, they reported total combined income of $30,610,
$34,126, $42,032, and $45,078, respectively.4 Petitioner’s
separate wage income during each of these years was $11,387,
$12,713, $15,906, and $16,708, respectively. The 1978, 1979, and
1980 joint returns were prepared by independent accountants or
tax return preparation services unaffiliated with Mr. Hoyt.
Starting with the 1981 return and continuing through at least
4The total income of $45,078 for 1981 is the income reported
by petitioner and Mr. Barnes prior to subtracting the partnership
loss of $29,520.
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