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A. Petitioner and Petitioner’s Husband
1. Petitioner
Petitioner resided in Martinez, California, when she filed
her petition. She married Richard Wiwi (Mr. Wiwi) on September
9, 1995. At the time of trial, they were still married and
living together.
Petitioner is a licensed clinical laboratory scientist. In
1995, she worked full time for the Blood Bank of Alameda/Contra
Costa Counties as a medical technologist and was eligible for
various employee benefits (not described further in the record).
Later in 1995, the blood bank changed her position to part time.
From 1997 to 1999, petitioner was employed in two temporary
medical technologist positions, and she received no employee
benefits.
2. Petitioner’s Husband
In 1995, Mr. Wiwi was the sole proprietor of a financial
services business. He was licensed to trade securities and sell
insurance. Petitioner knew about his business, but she did not
know how much he earned. He concealed from her the fact that he
had prior financial obligations, including unpaid income tax for
1993 and 1994.
3. Petitioner and Her Husband’s 1995 Tax Return
Taxes in the amount of $10,862 were withheld from
petitioner’s wages in 1995. Mr. Wiwi made no estimated tax
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