Philip Cullen - Page 4

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          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 of                 






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