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respondent’s favor; (3) whether the interest included in
petitioner’s income by respondent constituted interest on a joint
bank account belonging to petitioner and Mr. Quarterman with the
result that one-half of that interest is excludable from her
income; and (4) whether petitioner is liable for the additions to
tax.
FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference.
At the time the petition was filed, petitioner resided in
Washington, D.C.
Petitioner was employed as an architect by the Federal
Government, Department of Veterans Affairs, when, on October 27,
1992, at age 52, she retired on full disability. During 1995,
both petitioner and Mr. Quarterman were retired and receiving
pensions, she from the Federal Government and he from his former
employer, the District of Columbia. Mr. Quarterman died on
September 17, 2002.
Petitioner and Mr. Quarterman filed a joint Form 1040, U.S.
Individual Income Tax Return (joint return), for each of the
years 1994 and 1996, but respondent has no record that
petitioner filed a return (either separate or joint with
Mr. Quarterman) for 1995.
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