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Petitioner was employed as an office manager during 1995,
and appropriate amounts of Federal income tax were withheld from
her wages from that employment. Her former spouse was a self-
employed construction contractor during 1995. He made no
estimated quarterly tax payments with respect to his self-
employment income earned that year.
Petitioner and her former spouse maintained a joint checking
account throughout their marriage. Petitioner’s former spouse
controlled their personal finances and directed the payment of
all of the household expenses, which from time to time included
payments to respondent in accordance with installment agreements
in effect for different years. Petitioner was given a fixed
amount each month by her former spouse with which to purchase
groceries for the family. Petitioner did not have access to the
household checking account without the knowledge of her former
spouse. In addition, petitioner’s former spouse maintained a
separate checking account for his construction business.
Petitioner did not have access to the business checking account.
Petitioner and her former spouse filed joint Federal income
tax returns during their marriage. Petitioner’s former spouse
was responsible for the preparation and filing of the joint
returns. Their joint returns typically were untimely, and the
tax reported on those returns typically was not fully paid with
the return. Before 1995, petitioner’s former spouse negotiated
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