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6330(d) of respondent’s decision to proceed with collection of
petitioner’s Federal income tax liabilities for the 1991, 1992,
and 1993 tax years.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made a part hereof.
Petitioner’s legal residence at the time the petition was filed
was Bakersfield, California.
Petitioner was married to Zack Clark (Mr. Clark). Mr. Clark
died on October 25, 2001.2 During the years in issue, petitioner
was a housewife. Mr. Clark was self-employed as a mechanic in
1991 and operated a personnel and property management business
during 1991, 1992, and 1993.
Petitioner and Mr. Clark filed a joint Federal income tax
return for 1991 on July 3, 1996. The return showed a tax of
$2,938. This amount was not paid at the time of filing.
Petitioner and Mr. Clark filed a joint Federal income tax return
for 1992 on April 15, 1996. That return showed a tax of $9,141,
which was also not paid at the time of filing. Petitioner and
Mr. Clark filed a joint Federal income tax return for 1993 on
April 16, 1996. That return showed a tax of $6,798, which also
was not paid at the time of filing.
2Petitioner and Mr. Clark were divorced in 1984 but
remarried about 1 year later. For purposes of this proceeding,
however, petitioner was married to Mr. Clark during the years in
issue. Therefore, the divorce is not a factor to be considered
in deciding this case.
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