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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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Last modified: May 25, 2011