Sandra Browda, Petitioner, and David Browda, Intervenor - Page 5

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          jointly filed tax returns.                                                  
               Several times during the couple’s marriage, the California             
          Franchise Tax Board notified petitioner and her employer that her           
          wages would be subject to garnishment for intervenor’s share of             
          the unpaid State income taxes reported on their jointly filed               
          State income tax returns.  On each such occasion, petitioner                
          notified intervenor of the impending garnishment and intervenor             
          paid the State income taxes due.                                            
               Petitioner and intervenor filed joint Federal income tax               
          returns for the taxable years 1994, 1995, 1996, 1997, and 1998.             
          The tax returns were prepared by a paid income tax return                   
          preparer.  The 1994 tax return was filed on September 23, 1996;             
          the 1995 tax return was filed on October 21, 1996; and the 1996,            
          1997, and 1998 tax returns were filed on October 23, 2000.2                 
          After prepayments consisting principally of petitioner’s tax                
          withholdings, petitioner and intervenor reported the following              
          balances of tax due on each tax return:3                                    





               2  The 1994 tax return had no date with petitioner’s                   
          signature.  However, intervenor signed the 1994 tax return on               
          Sept. 17, 1996.  Petitioner signed the 1995 tax return on Oct.              
          14, 1996.  The 1996 tax return had no date with petitioner’s                
          signature.  However, intervenor signed the 1996 tax return on               
          Aug. 31, 1998.  Petitioner signed the 1997 return on Aug. 31,               
          1998.  Petitioner signed the 1998 return on Mar. 8, 2000.                   
               3  All amounts have been rounded.                                      





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