Gwendolyn A. Ewing - Page 4

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          payments to the United States and was not subject to withholding            
          in 1995.  Petitioner and Mr. Wiwi filed a joint Federal income              
          tax return for 1995.  On that return, they reported Federal                 
          income tax withheld on petitioner’s wages of $10,862 and                    
          additional tax due of $6,220.  However, they paid only $1,620               
          with their return; petitioner paid $1,069, and Mr. Wiwi paid                
          $551.  As a result of withholding and the payment with the                  
          return, petitioner paid an amount equal to the tax on her income,           
          but Mr. Wiwi paid less than the tax due on his income.                      
               Mr. Wiwi told petitioner (and she reasonably believed) that            
          he would pay the unpaid 1995 tax as provided in a proposed                  
          installment agreement that he submitted with their 1995 income              
          tax return.  Mr. Wiwi failed to pay the remaining 1995 tax, but             
          he concealed that fact from petitioner until 1998.  Early in                
          1999, he filed an offer in compromise in which he said he could             
          not pay the unpaid tax for 1995.                                            
               4.   Petitioner’s Finances                                             
               Petitioner and Mr. Wiwi have always kept their finances                
          separate.  Petitioner paid her own expenses (including Federal              
          income tax on her income) beginning before they were married and            
          continuing until the time of trial.  Petitioner paid at least               
          half of their household expenses from the date they were married            
          until 1997.  Mr. Wiwi began having medical problems in 1996.  He            
          lost his license to sell securities in 1997, and his income                 






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