- 4 - Financial Affairs During the early years of their marriage, petitioner and Ms. Cullen maintained a joint bank account with a single checkbook at Sunshine Bank in Pensacola, Florida. However, during 1999, petitioner deposited his monthly income in a checking account in his name at Regions Bank. Petitioner also testified and the Court so finds that during 1999 Ms. Cullen did not deposit her money into his Regions Bank account. He assumed that she had her own separate checking account. Petitioner did not benefit from any of Ms. Cullen’s 1999 TGY income since they did not live together at any time during or after 1999. Petitioner was left with all of their joint unpaid bills when Ms. Cullen moved out of their home, and their divorce decree did not address who was obligated to pay the 1999 taxes. As to the tax due on Ms. Cullen’s $23,603 of 1999 income, petitioner “just assumed that she [Ms. Cullen] was taking care of her own business”. He did not, however, verify this because he contended he “couldn’t get a hold [sic] of her” although she was living in the trailer next door. Request for Section 6015 Relief Because of the $23,603 of unreported income, respondent determined an income tax deficiency and statutory additions with respect to petitioner and Ms. Cullen’s 1999 tax year. Neither petitioner nor Ms. Cullen contested the statutory notice ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011