- 3 - Petitioner is a high school graduate who was employed as a librarian by a law firm during the taxable years in issue. Petitioner’s employer withheld taxes from her wages, and such withholding was more than sufficient to pay petitioner’s personal income tax liabilities. Intervenor is a college graduate who was self-employed as a salesman during the taxable years in issue. Intervenor did not make estimated quarterly tax payments in respect of his self-employment income; rather, he relied on petitioner’s excess withholding to satisfy, at least in part, his personal income tax liabilities. Petitioner and intervenor maintained separate bank accounts throughout their marriage. Petitioner primarily paid the monthly expenses related to their daughter. Intervenor was responsible for paying most of the household expenses, which included, among other things, the monthly home mortgage, property taxes, auto insurance, and household utilities. Petitioner and intervenor filed joint Federal and State income tax returns during their marriage. Petitioner did not participate in the preparation of any of their joint tax returns. Each year petitioner gave her Form W-2, Wage and Tax Statement, to intervenor who had the tax return prepared by a paid preparer. Petitioner willingly signed each tax return without meticulous examination. Prior to the taxable years in issue, intervenor paid all income tax balances due with respect to the couple’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011