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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner was a resident of Minneapolis, Minnesota.
Petitioner filed joint Forms 1040, U.S. Individual Income
Tax Return, with her spouse, Kenneth E. Sjodin (Mr. Sjodin) for
the taxable years 1987, 1988, 1990, and 1992. These returns each
reflected tax due which was not paid at the time of filing. The
amounts in question in this case relate to these returns and not
any additional deficiencies determined by respondent.
Petitioner and Mr. Sjodin were married for approximately 20
years at the time of the first year in question and remain
married. There is no evidence they have ever separated.
Petitioner and Mr. Sjodin have four children. In 1987, two were
in college and two were in high school. During the years in
question, petitioner and Mr. Sjodin jointly supported their
children and their household. Petitioner worked as a retail
clerk during the years in question and received wage income which
was subject to withholding. Mr. Sjodin had a real estate
business, and his income was not subject to withholding. The
unpaid liabilities are primarily the result of the income of Mr.
Sjodin.
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