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Petitioner’s former spouse was a farmer during most of the time
he and petitioner were married. At trial, when asked by her
attorney how she was employed during her marriage, petitioner
described herself as a “stay-at-home mom.” Although petitioner
did not participate in the farming operations, from time to time
during their marriage she and her former spouse discussed the
family’s financial situation.
For years prior to 1995, petitioner and her former spouse
filed joint Federal income tax returns and fully paid the
Federal income tax liabilities reported on those returns. Due
to financial difficulties apparently caused by the vagaries of
crop production, things changed in 1995.
For that year, as well as the next, the amount of tax shown
on the joint return of petitioner and her spouse was not fully
paid with the filing of the return. Of the $25,019 liability2
reported on their 1995 joint return, only $8,500 was paid with
the return. Apparently, the balance was paid through a series of
installment payments made during 1997 and 1998. On their 1996
joint return, they reported a tax liability of $26,527 but paid
only $12,919 with that return. During 1997, a $5,000 payment was
made towards the outstanding 1996 tax liability. It appears that
2 This amount does not include the “estimated tax penalty”
reported on the return.
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