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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’s
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